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HomeMy WebLinkAboutAQ_F_0300015_20221031_CMPL_InspRpt NORTH CAROLINA DIVISION OF Winston-Salem Regional Office AIR QUALITY International Pipes and Accessories LLC NC Facility ID 0300015 Inspection Report County/FIPS:Alleghany/005 Date: 10/31/2022 Facility Data Permit Data International Pipes and Accessories LLC Permit 04288/R13 1731 US Highway 21 South Issued 3/20/2018 Sparta,NC 28675 Expires 2/28/2026 Lat: 36d 29.3460m Long: 8ld 5.9280m Class/Status Small SIC: 2141 /Tobacco Stemming And Redrying Permit Status Active NAILS: 312229/Other Tobacco Product Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Rick Wooten Rick Wooten Denise Osborne MACT Part 63: Subpart 6J Plant Manager Plant Manager (336)372-5521 (336)372-5521 (336)372-5521 Compliance Data Comments: Inspection Date 10/26/2022 Inspector's Name Ryan Dyson Inspector's Signature: Z�� DMM Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: 10/31/2022 Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2016 0.4200 0.1600 0.0400 0.8730 0.0100 0.4100 1029.94 2012 0.6200 0.2600 0.0700 1.35 0.0150 0.6200 1464.62 *Highest HAP Emitted inpounds) Five Year Violation History:None Date Letter Type Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested 1 Permitted Sources Emission Source ID Emission Source Description Control System ID Control System Description CD-1 Bagfilter(3,240 square feet of filter area) ES-1 I Wood working operation CD-2 Bagfilter(3,240 square feet of filter area) CD-3 Bagfilter(3,840 square feet of filter area) FC-1,FC-2 Two flow coaters N/A N/A One pipe finishing operation,consisting of: CL-1 Charcoal lining machine N/A F N/A SB-1 Dry filter-type spray booth N/A N/A DR-1 Electrically-heated drying room N/A N/A DO-1 Electrically-heated drying oven N/A N/A Insignificant/Exempt Activities Source of Source of Title V Source Exemption Regulation TAPS? Pollutants? IES-1 -Propane gas/No.2 fuel oil-fired boiler F2Q .0102(h)(1)(A) Yes Yes (6.277 million Btu per hour maximum capacity) IES-3 -Aboveground, 10,000-gallon No.2 fuel oil storage tank I 2Q .0102(g)(4) FYes Yes IES-4-Aboveground, 1,000-gallon propane storage tank 2Q .0102(g)(4) No Yes IES-5 -Aboveground,250-gallon propane storage tank F 2Q .0102(g)(4) F No Yes IES-6-Parts washer 2Q .0102(h)(3) Yes Yes Introduction On October 26,2022,Mr.Ryan Dyson,Environmental Specialist for the Winston-Salem Regional Office of the North Carolina Division of Air Quality(WSRO-DAQ),met with Mr.Rick Wooten,Plant Manager,and conducted an unannounced Full Compliance Evaluation(FCE)of International Pipes and Accessories LLC.This facility was most recently inspected by Mr.Dyson on December 17,2019 and appeared to be operating in compliance with all applicable Air Quality standards and regulations at the time of that inspection.The facility manufactures wooden tobacco smoking pipes,with confirmed operating hours of 6:30 AM to 5:00 PM, Monday through Thursday,for 49 weeks per year.Mr.Wooten indicated that production at the facility has been relatively steady and estimated that the facility produces approximately 42,000 pipes per year.All IBEAM contact information was confirmed by Mr. Wooten at the time of this inspection.Mr.Wooten also stated that there have been no equipment or process changes since the last inspection. Safety Equipment Proper Personal Protective Equipment(PPE)for this facility includes safety glasses and hearing protection. Applicable Regulations Permit Condition A.1 states that the facility is subject to the following regulations:Title 15A North Carolina Administrative Code (NCAC), Subchapter 2D.0202,2D .0512,2D .0521,2D .0535,2D .0540,2D.0611,and 2D.1806. This facility is not subject to the Risk Management Plan(RMP)requirements of the 112(r)Program,as it does not purchase,produce,utilize,or store any of the regulated substances in quantities above their associated threshold limits.The facility is still subject to the General Duty clause in this rule. Discussion This facility manufactures wooden tobacco smoking pipes that are sold under the Dr.Grabow brand name.The process begins as the facility receives either shipments of briar wood in burlap bags from Greece and Italy,or shipments of pre-formed wooden bowls.Mr. Wooten stated that the facility has primarily switched to receiving mostly pre-formed wooden bowls.Therefore,Mr.Wooten indicated that they engage in far less wood forming work than they used to.If needed,however,the blocks can be shaped into specific pipe models using a wide assortment of specialized woodworking equipment(ES-1)for boring,trimming,detailing and fine sanding. The emissions from the woodworking operation are controlled by bagfilter unit CD-3. Some woodworking equipment was in operation at the time of this inspection,with its emissions being routed to bagfilter CD-3.Bagfilter CD-3 was observed in operation,with all 2 ductwork appearing to be maintained in proper working order,and no discernible visible emissions.The facility is also permitted for two other bagfilter units(CD-1 and CD-2).However,as confirmed from prior inspectors,these units have been taken out of service due to a decrease in production and reduction of process equipment over the years.Mr.Wooten estimated that CD-1 and CD-2 have been out of service for at least six years. The facility is permitted for two flow coaters(FC-1 and FC-2).These coaters are used to apply stain to the pipes. One flow coater coats the pipe,while the other is intended to clean off any excessive stain residue through the use of methanol.Both flow coaters were observed on-site,although neither was in operation at the time of this inspection.Mr.Wooten estimated that the flow coaters are typically only operated for approximately 3 hours,each,per week. The facility is also permitted for a charcoal lining machine(CL-1),a dry filter-type spray booth(SB-1),an electrically heated drying room(DR-1)and an electrically heated drying oven(DO-1).All this equipment was observed on-site,however none of it was in operation at the time of inspection.The charcoal lining machine,which would be utilized to spray a charcoal-based substance into the bowl of the pipe is no longer operational,as it has been partially deconstructed.Mr.Wooten stated that the facility simply conducts any necessary charcoal lining work by hand now.According to Mr.Wooten,the charcoal lining machine has not been in operation since 2015.The filters for the spray booth(SB-1)appeared to be in proper working order at the time of the inspection,with no discernible gaps or holes. This spray booth,which is used to spray apply lacquer to the wooden pipes,was not in operation at the time of this inspection.Mr.Wooten estimated that this spray booth is typically only used for approximately four to five hours per week. According to Mr.Wooten,the filters are cleaned approximately once per month and replaced semi-annually.The electrically heated drying oven(DO-1)is adjacent to the spray booth(SB-1)and was not in operation at the time of this inspection.The permitted drying room itself(DR-1)was observed on-site.However,this room is now strictly a storage room and is no longer vented to the atmosphere. The facility operates several exempt sources,including a propane gas/No.2 fuel oil-fired boiler(6.277 million Btu per hour maximum capacity)(IES-1),a I0,000-gallon aboveground No. 2 fuel oil storage tank(IES-3),a 1,000-gallon aboveground propane storage tank (IES-4),a 250-gallon aboveground propane storage tank(IES-5)and a parts washer(IES-6).Mr.Wooten confirmed that the boiler (IES-1)is used exclusively for comfort heat.Propane is combusted within the boiler for start-up purposes,before switching to No.2 fuel oil as the main combustion fuel.This boiler was not in operation at the specific time of this inspection.All fuel storage tanks were observed on-site,with no signs of leaks or vapor emissions.The parts washer was observed on-site;however,it was not in operation at the time of inspection.Mr.Wooten stated that the facility currently only uses hot water and baking soda in the washer to clean parts. The lid on the parts washer was closed at the time of this inspection.Mr.Wooten stated that Safety Kleen annually services the parts washer. Permit Conditions Condition A.2 contains the permit renewal and emission inventory requirement of 15A NCAC 2D .0202. To meet this requirement, the facility must submit a permit renewal request and air pollution emission inventory report for the 2024 calendar year at least 90 days prior to the expiration date of the permit. The current permit for this facility expires February 28,2026. The requirements of this condition were discussed with Mr.Wooten at the time of this inspection,and future compliance is anticipated.Although the facility's aggregate emissions of criteria pollutants are low,Mr.Wooten expressed his desire to maintain his permit in the event of potential future increases in demand. Condition A.3 contains the particulate control requirement of 15A NCAC 2D.0512,"Particulates from Wood Products Finishing Plants."To comply with this condition,the facility must not discharge particulate matter stemming from the working,sanding,or finishing of wood without providing for its collection,adequate duct work and properly designed collectors.All ductwork appeared to be maintained in proper working order at the time of inspection. Compliance with this condition is indicated. Condition AA contains the visible emissions control requirement of 15A NCAC 2D .0521.Visible emissions from emission sources manufactured after July 1, 1971,shall not exceed 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.No visible emissions were observed from any of the facility's emission sources,indicating compliance with this condition at the time of this inspection. Condition A.5 contains the notification requirement of 15A NCAC 2D.0535.To comply with this condition,the facility shall notify the Director of any excess emissions that last for more than four hours and that result from any malfunction,breakdown of process or control equipment,or any other abnormal circumstance.Mr.Wooten stated that there have been no such occurrences at the facility since the date of the last inspection. Compliance with this condition is indicated. 3 Condition A.6 contains the fugitive dust control requirement of 15A NCAC 2D .0540.To comply with this condition,the permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantiated complaints or excess visible emissions beyond the property boundary.No fugitive dust was observed at the time of this inspection,and there is no dust complaint history for this facility in IBEAM. Compliance with this condition is indicated. Condition A.7 contains the fabric filter requirements of 15A NCAC 2D.0611. To comply with this condition,the facility shall perform,at a minimum,an annual(for each 12-month period following the initial inspection)internal inspection of each particulate collection device system.Records of these inspections must be kept on-site.Mr.Wooten provided the facility's bagfilter inspection records as part of this inspection. It appears that the facility conducts internal inspections of their functioning bagfilter(CD-3)during their routine shutdown periods around July and December of each year. Since the last facility inspection,internal inspections of bagfilter CD-3 were documented on July 5,2022,December 24,2021 (changed the belt on the blower),July 6,2021,December 28, 2020,June 29,2020,and December 19,2019(changed air filter and tightened blower belts).The records state that during each internal inspection,the bags are checked for structural integrity and dust leaks,all mechanical aspects are properly lubricated,and all associated ductwork is inspected. Compliance with this condition is indicated. Condition A.8 contains the control and prohibition of odorous emissions requirement of 15A NCAC 2D .1806.To comply with this condition,the permittee must operate the facility in such a manner as to prevent odorous emissions from causing or contributing to objectionable odors beyond the property boundary.No discernible odors were detected during the approach to the facility,and there is no history of odor complaints in IBEAM pertaining to this facility.Compliance with this condition is indicated. NSPS/NESHAP Condition A.9 pertains to the Federal Rule Applicable to Sources Exempted from Air Permitting Requirements.The facility's Propane gas/No.2 fuel oil-fired boiler(6.277 million Btu per hour maximum capacity)(IES-1)is subject to 40 CFR 63-NESHAP Subpart JJJJJJ.The WSRO-DAQ received an initial notification from this facility on December 7,2011.The initial tune up was performed on March 19,2012,and the required Notification of Compliance Status was received by the WSRO-DAQ on March 21, 2012.To comply with this subpart,the facility must conduct biennial tune ups on IES-1.The facility must also maintain records of the notifications,tune ups,and any malfunctions or abnormalities.Mr.Wooten provided the facility's boiler tune-up records as part of this inspection.Mr.Wooten stated that the facility contracts CC Boiler to conduct the boiler tune-ups annually.According to the provided records,the facility's boiler was most recently tuned up on December 1,2021,January 19,2021,and November 8,2019.Combustion analysis results from each tune-up are maintained with the tune-up records. Compliance with this condition is indicated. Facility-Wide Emissions The following table,borrowed from Permit Review R13,written by Ms.Taylor Hartsfield,Former Compliance Supervisor for the WSRO-DAQ,conveys the facility's potential and actual emissions for the 2016 calendar year. Actual Emissions [tons/year] Potential Emissions [tons/year] Pollutant I CY2016 ( ) without controls or limits F with controls and limits PM 0.42 88 3.3 PMIo 0.41 F 88 2.8 SOZ 0.16 F 14 14 NO,, 0.04 3.9 3.9 CO 0.01 2.3 2.3 VOC 0.87 F 7.3 7.3 HAPTotat 0.60 F 5.2 5.2 HAPxigha,t(Methanol) 0.51 F 3.9 3.9 Permit Issues/Considerations There do not appear to be any permit issues/considerations associated with this facility. Stack Testing It does not appear that any stack testing has been conducted at this facility,according to the IBEAM database. 4 5 Year Compliance History This facility has not been issued a NOD,NOV,or NOWRE in the past 5 years. Conclusion Based on visual observations and record review,International Pipes and Accessories LLC appeared to be operating in compliance with all applicable Air Quality standards and regulations at the time of this inspection. 5