HomeMy WebLinkAboutAQ_F_0200034_20221117_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Hancock&Moore,LLC dba Hancock&Moore
Plant 2
Inspection Report NC Facility ID 0200034
Date: 11/09/2022 County/FIPS:Alexander/003
Facility Data Permit Data
Hancock&Moore,LLC dba Hancock&Moore Plant 2 Permit 02757/R13
165 Matheson Park Avenue Issued 12/31/2015
Taylorsville,NC 28681 Expires 6/30/2023
Lat: 35d 54.9186m Long: 81d 10.5594m Class/Status Small
SIC: 2512/Upholstered Household Furniture Permit Status Active
NAICS: 337121 /Upholstered Household Furniture Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Junior Matheson Junior Matheson Dennis Tart
MACT Part 63: Subpart 6J
Facility Supervisor Facility Supervisor Environmental Engineer
(828)495-8235 (828)495-8235 (828)326-8376
Compliance Data
Comments:
Inspection Date 11/09/2022
Inspector's Name Donna Cook
Inspector's Signature: Donna etwk ��`� Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: 11/17/22 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2014 15.88 0.0500 0.9300 0.0300 1.14 11.74 71.90
2009 9.30 0.0300 0.5000 0.0200 0.6100 6.87 92.72
*Highest HAP Emitted in pojjnds
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
06/04/2021 NOV 2D .1404 Recordkeeping:Reporting: Monitoring: 06/10/2021
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
Hancock&Moore, LLC dba Hancock&Moore Plant 2
November 9,2022
Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Tracking: X Date submitted for initial review 11/17/2022 _IBEAM WARNING/OB,NOD,NOV,NRE
X IBEAM Document
X IBEAM Inspection, list date inspected _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 Inspection Date 11/01/2024
Directions: From Mooresville Regional Office to Taylorsville,travel via Statesville Avenue;North
Broad Street and the name changes to Statesville Highway(Highway 115 North)and then to Charlotte
Highway(Highway 21 North and Highway 115 North); Interstate 77 North; Exit 51 (Hickory/Winston
Salem)-Interstate 40 West toward Asheville; off Interstate 40 West take Exit 148-W. Statesville/
Taylorsville US Hwy. 64/NC 90; turn right off exit ramp onto Taylorsville Road US Hwy. 64; 16.7 miles
turn right on exit 254-Taylorsville/Conover;turn right off exit ramp onto NC Hwy. 16 North; 0.6 mile
turn right onto Matheson Park Avenue and 0.1 mile on the right is the entrance to the facility. The street
address is 165 Matheson Park Avenue.
Safety Equipment: This company requires that safety glasses, safety shoes and ear protection be worn
by the inspector at this facility.
Safety Issues: No safety issues were noted by me during the inspection.
Lat/Long Coordinates: A review of the "Facilities Regulated by Air Quality" on the DAQ web site
indicates the facility's location is accurate and matches the facility's latitude and longitude coordinates
listed in IBEAM. No changes to the latitude and longitude coordinates of this facility are needed in
IBEAM. The latitude and longitude coordinates of this facility are not locked in IBEAM.
Email Contacts: The email contact information for the facility, authorized,technical, and invoice
contacts were verified by Mr. Dennis Tart of Century Furniture and Mr. Scott Warren,plant manager. I
changed the authorized and facility contact information to Mr. Scott Warren, plant manager, in IBEAM.
1. General Information:
The purpose of this site visit was to conduct a routine air quality inspection. Hancock & Moore,
LLC dba Hancock & Moore Plant 2 manufactures wooden furniture frames to be sold for
residential use. This company had planned to sell the business. Plant No. 2 did not operate from
October 2021 through June 2022 but resumed operations in July 2022. The facility is currently
operating from 6:30 am to 4 pm, Monday through Thursday and 6:30 am to 10:30 am on Friday,
49 weeks per year. Mr. Dennis Tart, environmental engineer of Century Furniture; Mr. Scott
Warren, plant manager; and Mr. Tony Hollis, maintenance manager, accompanied me during this
inspection.
Hancock&Moore, LLC dba Hancock&Moore Plant 2
November 9, 2022
Page 3
2. Facility Contact Information:
During the inspection, I verified the facility contact information in IBEAM with Mr. Tart and Mr.
Warren. I changed the authorized and facility contact information to Mr. Scott Warren in
IBEAM.
3. Compliance history file review:
A Notice of Violation (NOV) dated June 4, 2021 was issued to this company for failure to
perform annual inspections and maintenance of the cyclones (ID Nos. CD-2, CD-3 and CD-4),
dynavane (ID No. CD-5) and fabric filter (CD-6) as required by 15A NCAC 2D .0611
Monitoring, Recordkeeping and Reporting and specified in Air Permit No. 02757R13 Specific
Condition and Limitation Nos. A. 10, 11 and 12.
4. Observations of permitted air emission sources and control devices:
Emission Emission Source Control Control System
Source ID Description System ID Description
1 (NESHAP) rB
ood-fired boiler(1.6 million
u per hour maximum heat N/A N/A
put)
The wood-fired boiler(ID No. 1)was removed and replaced with a permit exempt Cleaver Brooks
model natural gas-fired boiler(9,875,125 Btu per hour maximum heat input; model 9 CD 200-236-150;
serial# OL098738; 150 maximum psi rating and mfg. date on plate: 9/21/2010) during the months of
January and February 2016.
During the next permit revision, the wood-fired boiler(ID No. 1) and its specific permit
conditions and limitations Nos.A. 3,5,7 and 13 will need to be removed by MRO DAQ
permitting. The permit request change has been placed in the facility's electronic yellowsheet.
Observed. The wood-fired boiler(ID No. 1)was removed from this facility during the months of
January and February 2016. I observed no wood-fired boiler at this facility during the inspection.
W-1 f woodworking operation CD-2 cyclone(114 inches in
diameter)
W-2 woodworking operation CD-3 cyclone(114 inches in
diameter)
W-3 woodworking operation CD-4, CD-5, CD-6 cyclone(40 inches in
diameter, ID No. CD-4),
dynavane (three single
cells, ID No. CD-5), and
bagfilter(85 square feet of
filter area, ID No. CD-6),
installed in series
Various woodworking equipment such as saws, board machines, sanders, planers and shapers vent to
two cyclones (ID Nos. CD-2 and CD-3; 114 inches in diameter). The top of the two cyclones (ID Nos.
CD-2 and CD-3) exhaust through a vertical and uncapped stack to the outdoor atmosphere. From the
(bottom of the two cyclones(ID Nos. CD-2 and CD-3), the woodwaste is blown by fan to a closed loop
Hancock&Moore, LLC dba Hancock&Moore Plant 2
November 9, 2022
Page 4
cyclone(ID No. CD-4; no stack exhaust) located on top of an enclosed storage bin. At the bottom of
the closed loop cyclone(ID No. CD-4),the woodwaste is deposited into an enclosed storage bin. At
the top of the closed loop cyclone(ID No. CD-4), it vents to the Camfil Farr model dynavane(inertial
separator air cleaner with three single cells; ID No. CD-5). The dynavane vents through a horizontal
and louvered stack to the outdoor atmosphere.
Any woodwaste from the closed loop cyclone(ID No. CD-4) is blown by fan to the reverse air type
bagfilter(ID No. CD-6; no stack exhaust from it) located on top of an enclosed storage bin. At the
bottom of the reverse air type bagfilter,the woodwaste is deposited into the enclosed storage bin.
The bagfilter vents to the dynavane (ID No. CD-5),which exhaust through a horizontal and lovered
stack to the outdoor atmosphere.
Observed. Various woodworking equipment, three cyclones (ID Nos. CD-2, CD-3 and CD-4),
dynavane(ID No. CD-5) and bagfilter(ID No. CD-6)were operation at the time of the inspection. I
observed no visible emissions from these sources.
5. Observations of insignificant air emission sources and control devices listed on the current permit:
Source Exemption Regulation Source of Source of Title VTAPS? Pollutants?
IES-1 —wood gluing operation 2Q .0102 (c)(2)(D)(i) No . No
A glue(product name: Permaset 3054; manufacturer: Tailored Chemical Products,'Inc. and ingredient
name: vinyl acetate polymer) is applied by a brush to the joints of wooden furniture frames. A copy of the
SDS is in the file of this facility. Any emissions emitted from the gluing process is fugitive inside of this
facility. It was estimated by Mr. Tart and Mr. Warren that the glue usage is gallon or less per day.
Observed. I observed an employee brushing glue into the joints of a chair frame. No odorous emissions
were detected by me inside or outside of this facility.
6. Observations of air emission sources and control devices not listed on the current permit:
a. A natural gas-fired Cleaver Brooks boiler(9,875,125 Btu per hour maximum heat input;
model#CD 200-236-150; serial# OL098738; 150 maximum psi rating and mfg. date on
plate: 9/21/2010)replaced the wood-fired boiler(ID No. 1) during the months of January
and February 2016. The natural gas-fired boiler is exempt per 15A NCAC 2Q .0102
(h)(1)(B). The natural gas-fired boiler was in operation at the time of the inspection. I
observed no visible emissions from the vertical and capped stack of the natural gas-fired
boiler.
During the next revision,the permit exempt natural gas-fired boiler will need to be
added to the insignificant/exempt activities in the permit attachment. The permit
request change has been placed in the facility's electronic yellowsheet.
7. Compliance with specific permit conditions and limitations:
a. Condition A. 2. Permit Renewal and Emission Inventory Requirement—The pennittee
at least 90 days prior to the expiration date of this permit, shall request permit renewal by
letter with an application form and submit the air pollution emission inventory report
with certification sheet for 2022 calendar year to MRO DAQ.
Hancock&Moore,LLC dba Hancock&Moore Plant 2
November 9, 2022
Page 5
Observed. I informed Mr. Dennis Tart, environmental engineer for Century Furniture,
and Mr. Scott Warren,plant manager,that the current air permit expires on June 30, 2023
and the air pollution emission inventory report with certification sheet for 2022 calendar
year must be submitted with the permit renewal request. I advised Mr. Tart and Mr.
Warren to contact Jennifer Manning if there are any questions regarding air quality
permitting. Compliance with this stipulation is indicated.
b. Condition A. 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(1.6 million Btu per hour maximum 1.05
heat input)(1) i
Observed. This condition will no longer applies since the wood-fired boiler(ID No. 1)
has been removed by this facility. This condition needs to be removed and permit
change request has been placed in the facility's electronic yellowsheet. Compliance
with this stipulation was determined during the permit application process.
C. Condition A. 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 minimum for its collection, adequate duct work and properly designed
collectors, or other such devices as approved by the Commission.
Observed. The three cyclones (ID Nos. CD-2, CD-3 and CD-4), dynavane(ID No. CD-
5) and bagfilter(ID No. CD-6) are considered adequate collectors for particulate matter.
Compliance with this stipulation is indicated.
d. Condition A. 5. Sulfur Dioxide Control Requirement - As required by 15A NCAC 2D
.0516 "Sulfur Dioxide Emissions from Combustion Sources," the sulfur dioxide
emissions from the combustion sources shall not exceed 2.3 pounds per million Btu heat
input.
Observed. This condition will no longer apply since the wood-fired boiler(ID No. 1)
has been removed from this facility. This condition needs to be removed and permit
change request has been placed in the facility's electronic yellowsheet. Compliance
with this stipulation was indicated during the permit application process.
e. Condition A. 6. Visible Emissions Control Requirement-As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," the visible emissions from the woodworking
operations(ID Nos. W-1, W-2 and W-3) manufactured after July 1, 1971, are limited to
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.
Hancock&Moore,LLC dba Hancock&Moore Plant 2
November 9, 2022
Page 6
Observed. No visible emissions were observed by me at the facility. Compliance with
this stipulation is indicated.
f. Condition A. 7. Visible Emissions Control Requirement-As required by 15A NCAC 2D
.0521 "Control of Visible Emissions" states that the visible emissions from the wood-
fired boiler(ID No. 1), manufactured as of July 1, 1971, are limited to 40 percent opacity
when averaged over a six-minute period, except that six-minute periods averaging not
more than 90 percent opacity may occur not more than once in any hour nor more than
four times in any 24-hour period.
Observed. This condition will no longer applies since the wood-fired boiler(ID No. 1)
has been removed by this facility. This condition needs to be removed and permit
change request has been placed in the facility's electronic yellowsheet. Compliance
with this permit condition is indicated.
g. Condition A. 8.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 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.
Observed. Based on a records review and conversation with Mr. Tart,Mr. Warren and
Mr. Hollis, no excess emissions have occurred at the facility. Compliance with this
stipulation is indicated.
h. Condition A. 9. Fugitive Dust Control Requirement-As required by 15A NCAC 2D
.0540 "Particulates From Fugitive Dust Emissions 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).
Observed. MRO DAQ has not received any fugitive dust emissions complaints
regarding this facility. This company has a paved road in front of the facility and
unpaved areas rear the rear of this facility. During the inspection,I observed no fugitive
dust emissions from this facility. Compliance with this stipulation is indicated.
i. Condition A. 10. Cyclone Requirements-As required by 15A NCAC 2D .0611 states
that the particulate matter emissions shall be controlled as described in the equipment list.
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 as recommended by the
equipment manufacturer. The results of all inspections and maintenance activities shall
be investigated with corrections made and dates of actions recorded in a logbook. The
Hancock&Moore, LLC dba Hancock&Moore Plant 2
November 9,2022
Page 7
logbook(in written or electronic format) shall be kept on-site and made available to DAQ
personnel upon request.
Observed. The records provided by this company indicated that the inspection and
maintenance activities are being performed on the three cyclones(ID Nos. CD-2, CD-3
and CD-4). This company conducted inspections of the three cyclones on 10/18/22;
1/25/22 and previously on 6/7/21. The inspections of the three cyclones were each within
the 12 month period time frame as indicated by this condition.
This facility is required by General Condition and Limitation B. 2. of the current permit
to keep records on site for a minimum of two years. The records for the inspection and
maintenance activities of the three cyclones are being kept by this company more than
two years. Compliance with this stipulation is indicated.
j. Condition A. 11. Fabric Filter Requirements includingcartridge artridge filters, baghouses, and
other dry filter particulate collection devices-As required by 15A NCAC 2D .0611,the
particulate matter emissions shall be controlled as described in the permitted equipment
list. To comply with the provisions of this permit and ensure that emissions do not
exceed the regulatory limits,the pennittee shall perform, at a minimum, an annual (for
each 12 month period following the initial inspection) internal inspection of each
particulate collection device system within a 12 month period following the initial
inspection. In addition,the permittee shall perform periodic inspections and maintenance
as recommended by the equipment manufacturer. The results of all inspections and
maintenance activities shall be investigated with corrections made and dates of actions
recorded in a logbook. The logbook(in written or electronic format)shall be kept on-site
and made available to DAQ personnel upon request.
Observed. The records provided by this company indicated that the inspection and
maintenance activities and internal inspections are being performed on the bagfilter(ID
No. CD-6) by this company. The internal inspections of the bagfilter were conducted on
10/18/22; 1/25/22 and previously on 6/7/21. The internal inspections of the bagfilter were
within the 12 month period time frame as indicated by this condition.
This facility is required by General Condition and Limitation B. 2. of the current permit
to keep records on site for a minimum of two years. The records for the inspection and
maintenance activities of the bagfilter are being kept by this company more than two
years. Compliance with this stipulation is indicated.
k. Condition A. 12. Dynavane Requirements—As required by 15A NCAC 2D .0611,the
particulate matter emissions shall be controlled as described in the permitted equipment
list. To comply with the provisions of this permit and ensure that emissions do not
exceed the regulatory limits, the permittee shall perform, at a minimum, an annual(for
each 12 month period following the initial inspection) internal inspection of dynavane
system. In addition,the permittee shall perform periodic inspections and maintenance as
recommended by the equipment manufacturer. The results of all inspections and
maintenance activities shall be investigated with corrections made and dates of actions
recorded in a logbook. The filter logbook(in written or electronic format)shall be kept
on-site and made available to DAQ personnel upon request.
Hancock&Moore, LLC dba Hancock&Moore Plant 2
November 9,2022
Page 8
Observed. The records provided by this company indicated that the inspection and
maintenance activities and internal inspections are being performed on the dynavane(ID
No. CD-5) by this company. The internal inspections of the dynavane were conducted on
10/18/22; 1/25/22 and previously on 6/7/21. The internal inspections of the dynavane
were within the 12 month period time frame as indicated by this condition.
This facility is required by General Condition and Limitation B. 2. of the current permit
to keep records on site for a minimum of two years. The records of the dynavane
inspection and maintenance activities are being kept by this company for more than two
years. Compliance with this stipulation is indicated.
1. Condition A. 13. Generally Available Control Technology-For the wood-fired boiler(ID
No. 1),the permittee shall comply with all applicable provisions, including the
notification,testing, and monitoring requirements contained in Environmental
Management Commission Standard 15A NCAC 2D .l 111, 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."
Observed. This condition no longer applies since the wood-fired boiler(ID No. 1)
has been removed from this facility. This condition needs to be removed and permit
change request has been placed in the facility's electronic yellowsheet. Compliance
with this stipulation is indicated.
8. NSPS/NESHAP Review:
This facility has no reciprocating internal combustion engines or generators,fire pump engines,
or gasoline storage tanks.
The wood-fired boiler(ID No. 1)has been removed from this facility. It is no longer subject to
the National Emission Standards for Hazardous Air Pollutants(NESHAP)for Industrial,
Commercial, and Institutional Boilers Area Sources(40 CFR Part 63, Subpart JJJJJJ or 6J).
The permit exempt natural gas-fired boiler is not subject to the National Emission Standards for
Hazardous Air Pollutants(NESHAP)for Industrial, Commercial, and Institutional Boilers Area
Sources (40 CFR Part 63, Subpart JJJJJJ or 6J), since the rule does not apply to a boiler that is
gas-fired.
The permit exempt natural gas-fired boiler is not subject to NSPS 40 CFR Part 60, Subpart Dc-
"Standards of Performance for Small-Industrial-Commercial-Institutional Steam Generating
Units," since the regulation applies to a boiler constructed after June 9, 1989 and a maximum heat
input capacity greater than 10 million Btu per hour. The boiler was constructed during January
and February 2016 and the maximum heat input capacity is 9,875,125 Btu per hour. It met the
construction date but the maximum heat input capacity of this boiler was not greater than 10
million Btu per hour.
Hancock&Moore,LLC dba Hancock&Moore Plant 2
November 9,2022
Page 9
9. Summary of changes needed to the current permit:
a. The wood-fired boiler(ID No. 1)and its specific permit conditions and limitations Nos.
A. 3, 5, 7 and 13 will need to be removed by MRO DAQ permitting. The permit request
change has been placed in the facility's electronic yellowsheet.
b. The permit exempt natural gas-fired Cleaver Brooks boiler rated 9,875,125 Btu per hour
maximum heat input will need to be added to the insignificant/exempt activities in the
pen-nit attachment. The permit request change has been placed in the facility's electronic
yellowsheet.
10. Compliance assistance offered during the inspection:
Air Permit No. 02757R13 will expire on June 30,2023. Specific Condition and Limitation
No. A. 2. "Permit Renewal and Emission Inventory Requirement" states that the permittee request
permit renewal by letter along with an application form and submit air pollution emissions
inventory report for the 2022 calendar year with certification sheet at least ninety(90) days prior
to the expiration date of the permit. I discussed the permit renewal requirements with Mr. Tart
and Mr. Warren.
11. Section 112(r) applicabilitX:
This facility does not appear to be subject to the requirements of the Chemical Accident Release
Prevention Program, Section 112(r) of the Clean Air Act.
12. Compliance determination:
Based on my observations,this facility appeared to be in compliance with the applicable air
quality regulations at the time of the inspection.
DLC:
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