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