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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: c: Laserfiche https://nceonnect.sharepo int.coin/sites/DAQ-MRO/Counties/ALEY,ANDER/00034/INSPECT_20221109.doex