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HomeMy WebLinkAboutAQ_F_1400226_20221129_PRMT_PmtRvw_R01 NORTH CAROLINA DIVISION OF Region: Asheville Regional Office AIR QUALITY County: Caldwell Application Review NC Facility ID: 1400226 Inspector's Name: Bob Graves Date of Last Inspection: 02/22/2022 Issue Date: November 29,2022 Compliance Code: 3/Compliance- inspection Facility Data Permit Applicability(this application only) Applicant(Facility's Name): Caldwell Cabinets of NC,LLC SIP: Yes NSPS: No Facility Address: NESHAP: No Caldwell Cabinets of NC,LLC PSD: No 3441 Hickory Blvd. SW PSD Avoidance: No Hudson,NC 28638 NC Toxics: No 112(r): No SIC: 2434/Wood Kitchen Cabinets Other: N/A NAICS: 33711 /Wood Kitchen Cabinet and Countertop Manufacturing Facility Classification: Before: Small After: Small Fee Classification: Before: Small After: Small Contact Data Application Data Facility Contact Authorized Contact Technical Contact Application Number: 1400226.22A James Hamrick Amy Moore James Hamrick Date Received: 08/19/2022 Operations Manager Member Officer Operations Manager Application Type: Renewal (828)455-1842 (828)244-2975 (828)455-1842 Application Schedule: State PO Box 547 po Box 547 PO Box 547 Existing Permit Data Hudson,NC 28638 Hudson,NC 28638 Hudson,ITC 28638 Existing Permit Number: 10413/R00 Existing Permit Issue Date: 12/09/2014 Existing Permit Expiration Date: 11/30/2022 Review Engineer: Amro Ali Comments/Recommendations: Issue 10413/R01 Review Engineer' Signat e: Date: Permit Issue Date: November 29,2022 f Permit Expiration Date: October 31,2030 V l f12-q L 1. Purpose of Request This application is made to renew the air quality permit for a woodworking facility in Hudson. This facility manufactures wooden kitchen cabinets and has the following permitted sources: Emission Emission Source i Control Control System j Source ID Description System ID Description ES-1 ;woodworking and dust collection system I CD-1 Fnebagfilter square feet of filter area) 2. Application Chronology August 19,2022 ARO received the permit renewal application; October 28,2022 ARO contacted the facility to ask whether they want to rescind the permit; clock off, November 17,2022 The facility responded that they want to keep the permit;clock on; November 29,2022 Permit issued. Caldwell Cabinets of NC, LLC Hudson Page 2 of 3 3. Regulatory Review The facility must comply with the following EMC Regulations for this application: 15A NCAC 2D .0512,"Particulates from Wood Products Finishing Plants"; 15A NCAC 2D.052 1,"Control of Visible Emissions"; 15A NCAC 2D .0535,"Excess Emissions Reporting and Malfunctions"; 15A NCAC 2D .0540,"Particulates from Fugitive Dust Emission Sources"; 15A NCAC 2D .0611,"Baghouse Monitoring and Maintenance Requirements"; 15A NCAC 2D .1806,"Control and Prohibition of Odorous Emissions";and 4. Compliance Determination 2D.0512-Particulates from Wood Products Finishing Plants-This regulation requires that adequate ductwork and control devices be used to minimize particulate emissions from the working,sanding or finishing of wood.The baghouse installed on the woodworking operation should provide adequate control for the wood waste generated by the processes at this facility. The facility appeared to be in incompliance during the last compliance inspection. Compliance is expected and will be verified during annual compliance inspections. 2D.0521 -Control of Visible Emissions-In order to comply with 2D .0521,the visible emissions from the facility shall not be more than 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 for sources manufactured as of July 1, 1971. For sources at the facility manufactured after July 1, 1971,visible emissions shall not be more than 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. It is assumed that all equipment setup at this facility was new at the time of installation and is therefore subject to the 20 percent opacity standard. The facility appeared to be in in compliance during the last compliance inspection. Compliance with 2D.0521 is expected and will be verified by inspection. 2D.0535 -Excess Emissions Reporting and Malfunctions-This regulation requires timely reporting and appropriate actions during periods of excess emissions and malfunctions.Compliance with Rule 2D .0535 is expected. 2D.0540-Particulates from Fugitive Dust Emission Sources-The regulation addresses all facilities with activities such as:unloading and loading areas,process areas,stockpiles,stockpile working,plant parking lots,and plant roads (including access roads and haul roads). The regulation requires a fugitive process dust plan and abatement measures if substantive complaints are verified. The facility appeared to be in incompliance during the last compliance inspection. Compliance with 2D .0540 is expected and will be verified during onsite inspections. 2D .0611 -Baghouse and Cyclone Monitoring and Maintenance Requirements-This regulation requires the Permittee to conduct,at a minimum,annual internal inspections of the baghouse(ID No.CD-1)connected to the woodworking and wood waste handling system(ID No.ES-1). The Permittee shall maintain a logbook documenting inspections and any variance from the manufacture's recommendation. The facility appeared to be in incompliance during the last compliance inspection.Compliance with 2D .0611 will be verified by inspection. 2D.1806-Control and Prohibition of Odorous Emissions-The purpose of this rule is to provide for the control and prohibition of objectionable odorous emissions. The permit condition states,"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." The facility did not receive any odor complaints during the past five years. The facility appeared to be in incompliance during the last compliance inspection. Complaints will be addressed through on-site investigation, including an odor evaluation if necessary. Compliance with Rule 2D .1806 is expected. Caldwell Cabinets of NC, LLC Hudson Page 3 of 3 5. NSPS,NESHAPS,PSD,Toxics and 112(r)and Attainment Status The facility is not subject to the requirements of NSPS,NESHAPS/MACT, PSD, Toxics or 112(r). Based on this facility's potential emissions shown below,this facility is not a PSD major source. 6. Facility Compliance Status The facility was last inspected on February 22,2022,and this facility appeared to be operating in compliance with the Air Quality standards and regulations at the time of this inspection. The facility did not receive any violations during the past five years. 7. Facility Emissions Review Based on the potential facility-wide emissions shown below in the following table,this facility is classified as "small". Note that the facility qualifies for a permit exemption according to 2Q .0102(d). However,the facility decided to continue having an air quality permit,based on a phone call conversation with the facility on November 17,2022. ft M� ?AX�ti ,x.i MRs7FM.ijJ i PM 0.06 ton 78.97 tons 0.08 ton PM 10 0.0 ton 9.06 tons 0.05 ton VOC 2.1 tons 7.36 tons 7.36 tons Largest HAP 0.13 ton 0.44 ton 0.44 ton Toluene 252 pounds 882 pounds 882 pounds Total HAPs 0.17 ton 0.58 ton 0.58 ton 332.42 pounds 1,163 pounds 1,163 pounds Based on the January 8,2017 inspection report,the facility added a dry-filter spray booth in 2016. However,the spray booth was exempted from permitting,based on actual VOC emissions in 2017. The facility-wide actual VOC emissions are less than 5 tons per year;therefore,the dry-filter spray booth is exempted from permitting per 2Q .0102(h)(3). The spray booth will be added to the insignificant equipment list for this permit renewal. The PM potential emissions were adopted from the last permit review. The VOC potential emissions are based on the 2021 actual VOC emissions. By scaling the actual VOC emissions to 8760/2500 hours per year,the potential VOC emissions are 2.1 X(8760/2500)=7.36 tons. The potential HAP emissions were calculated by scaling to 8760/2500 hours. 8. Stipulation Review • The facility's dry-filter spray booth,which was added in 2016, is added to the insignificant equipment list for this permit review. • This Permit contains an emissions inventory requirement for the 2029 calendar year as part of the next renewal in 2030. 9. Conclusions, Comments,and Recommendations I checked the NC Secretary of State Webpage on November 21,2022 and verified that Caldwell Cabinets of NC, LLC is registered as a corporate entity. ARO will issue air permit 10413ROI to Caldwell Cabinets of NC, LLC in Hudson,Caldwell County,North Carolina. Comprehensive Application Report for 1400226.22A 11/29/2022 Caldwell Cabinets of NC, LLC-Hudson(1400226) Caldwell County General Information: Permit/Latest Revision: 10413/RO1 Application Dates Permit code: State Received Completeness Due Clock Start Calculated Issue Due Application type: Renewal 08/19/2022 10/03/2022 08/19/2022 12/08/2022 Engineer/Rev. location: Amro Ali/ARO Fee Information Regional Contact: Initial amount: Date received: Amount Due: Add. Amt Rcv'd: Date Rcv'd: Facility location: Asheville Regional Office $0.00 08/19/2022 0.00 Current Class/Status: Small Fund type: Deposit Slip#: Location rec'd: Location deposited: Clock is ON Application is COMPLETE 2331 Status is : Issued Contact Information Type Name Address City State ZIP Telephone Technical/Permit James Hamrick,Operations Manager PO Box 547 Hudson,NC 28638 (828)455-1842 Authorized Amy Moore, Member Officer po Box 547 Hudson,NC 28638 (828)244-2975 Acceptance Criteria Received? Acceptance Criteria Description Completeness Criteria Yes Authorized signature Received? Complete Item Description Yes Emissions Inventory Rec'd-Renewal Only 1 Comprehensive Application Report for 1400226.22A 11/29/2022 Caldwell Cabinets of NC,LLC-Hudson(1400226) Caldwell County Application Events Event Start Due Complete Comments Staff Acknowledgment letter due 08/19/2022 08/29/2022 08/24/2022 appears complete pvballard Technical additional information request 10/28/2022 11/27/2022 11/17/2022 afali Permit issued 11/29/2022 11/29/2022 pvballard 2 Comprehensive Application Report for 1400226.22A 11/29/2022 Caldwell Cabinets of NC,LLC-Hudson(1400226) Caldwell County Class before: Small Class after: Small Permit/Revision: 10413/ROI 2Q.0711: No 2D .1100: No Revision Issue Date: 11/29/2022 NSPS: No NESHAPS/MACT: No PSD/NSR: No Accumulated process days(includes public notice periods): 81 PSD/NSR Avoid: No Prohibitory Small: No Public notice/hearing/add info after 80 days: PSD/NSR Status After: Minor General permit: No Manager's discretion: Appealed? No Multi-site permit: No Multi.permits at facility: No Current Permit Information: Quarry permit: No Recycled Oil Condition: No Issue Effective Expiration Revision# SB3 BACT: No HAP Major(10/25 tpy): Minor 11/29/2022 11/29/2022 10/31/2030 RO1 2Q .0705 Last MACT/Toxics: NO NESHAPS/GACT: NO New Source RACT/LAER: NO Existing Source RACT: NO RACT/LAER Added Fee: NO RACT Avoidance: NO TV ACI : NO 2Q.0702 (a)(18)-Toxics/Combustion Source(s)After 07/10/10: NO 1120)/112(d): NO Regulations Pertaining to this Permit Reference Rule Regulation Description 2D .1806 Control And Prohibition of Odorous Emissions 2D .0611 Monitoring Emissions from Other Sources 2D .0202 Registration of Air Pollution Sources 2D .0512 Particulates from Wood Products Finishing Plants 2D .0521 Control of Visible Emissions 2D .0535 Excess Emissions Reporting and Malfunctions Comprehensive Application Report for 1400226.22A 11/29/2022 Caldwell Cabinets of NC,LLC-Hudson(1400226) Caldwell County Audit Information Pertaining to this Application Column Name Date Changed Old Value New Value Editor j 4 'j Comprehensive Application Report for 1400226.22A 08/23/2022 Caldwell Cabinets of NC,LLC-Hudson(1400226) Caldwell County General Information: Permit/Latest Revision: 10413/R00 Application Dates Permit code: State Received Completeness Due Clock Start Calculated Issue Due Application type: Renewal 08/19/2022 10/03/2022 08/19/2022 11/17/2022 Engineer/Rev. location: Amro Ali/ARO Fee Information Regional Contact: Initial amount: Date received: Amount Due: Add.Amt Rcv'd: Date Rcv'd: Facility location: Asheville Regional Office $0.00 08/19/2022 0.00 Current Class/Status: Small Fund type: Deposit Slip#: Location rec'd: Location deposited: Clock is ON Application is COMPLETE 2331 Status is : In progress Contact Information Type Name Address City State ZIP Telephone Technical/Permit James Hamrick,Operations Manager PO Box 547 Hudson,NC 28638 (828)455-1842 Authorized Amy Moore,Member Officer po Box 547 Hudson,NC 28638 (828)244-2975 Acceptance Criteria Received? Acceptance Criteria Description Completeness Criteria Yes Authorized signature Received? Complete Item Description Yes Emissions Inventory Rec'd-Renewal Only 1 STATE ¢ROY COOPER Uuvernur ELIZABETH S. BISER .4ecretury MRti R�# MICHAEL A.ABRACZINSKAS QUAM Director NORTH CAROLINA Environmental Quality August 24, 2022 Ms.Amy Moore Member Officer Caldwell Cabinets of NC, LLC PO Box 547 Hudson,NC 28638 SUBJECT: Receipt of Permit Application Renewal of Permit No. 10413R00 Application No. 1400226.22A Caldwell Cabinets of NC, LLC Facility ID: 1400226, Hudson, Caldwell County Dear Ms. Moore: Your air permit application (1400226.22A) for Caldwell Cabinets of NC, LLC, located in Caldwell County,North Carolina was received by this division on August 19, 2022. This application submittal did contain all the required elements and has been accepted for processing. Your application will be considered complete as of August 19, 2022, unless informed otherwise by this office within 45 days. Should you have any questions concerning this matter, please contact Amro Ali at 828-296-4500 or by email at amro.ali@ncdenr.gov. Sincerely, Brendan G. Davey, P.E., Regional Supervisor Division of Air Quality,NCDEQ cc: Asheville Regional Office Files North Carolina Department of Environmental Quality I Division of Air Quality DIEQ' Asheville Regional Office 12090 U.S.Highway 70 1 Swannanoa,NC 28778 828.296.4500 T 1828.299.7043 F NO3TH CAROLINA Deperhnent of Em um wW Qua ROY COOPER Governor ELIZABETH S. BISER Secretary Q�c+M MICHAELA.ABRACZINSKAS NORTH CAROLINA Director Environmental Quality May 18, 2022 Ms.Amy Moore Member Officer Caldwell Cabinets of NC, LLC P.O. Box 547 Hudson, NC 28638 SUBJECT: Air Permit Renewal Reminder and Emission Inventory Due Notification Caldwell Cabinets of NC, LLC Air Quality Permit No. 10413R00 Facility ID: 1400226, Hudson, Caldwell County Fee Classification: Small Dear Ms. Moore: This letter is to remind you that Air Permit No. 10413R00 will expire on November 30, 2022. Your permit renewal request, including an emission inventory, must be received by this office no later than September 1,2022. If no alterations or modifications have been made to the currently permitted sources,you may apply for renewal, at no cost, by submitting one original copy of application Form A. This form is available at https://deq.iic. ov/airqualitypermitlorms. If you would not like to renew your permit, please inform this office in writing. If any modifications have been made or new equipment is to be installed,you may be required to file a permit modification application. Please contact Patrick Ballard at 828-296-4500 to determine if you are required to submit an application. Under the authority of Title 15A NCAC 2D .0202,you are also required to provide an air quality point source emission inventory, quantifying actual air pollutant emissions for Calendar Year(CY) 2021. You must complete and submit the emission inventory even if your facility did not operate in CY 2021. The DAQ has implemented a web-based (Internet)tool named Air Emissions Reporting On-line (AFRO) at litips://xapps.ncdenr.org/a.q/aero/. You may print the required emission inventory forms or you may use the on-line submittal capability of AFRO. This system, detailed instructions, pollutant lists, and other relevant materials for your facility can be accessed through the same web page. Your facility ID and Personal Identification Number(PIN)to access this secure Internet site are 1400226 and gsRHBC6e9g,respectively. If you do not have access to a computer and/or the Internet, and would like further guidance, please contact Michael Koerschner at 828-296-4550. If you choose to submit paper emission inventory forms,you must submit one complete original copy by September 1,2022. If you use the AERO on-line submittal,the "submit" process must be completed by the same due date. An automated e-mail will be sent to confirm DAQ receipt of your on-line submittal. North Carolina Department of Environmental Quality I Division of Air Quality Asheville Regional Office 12090 U.S.Highway 70 1 Swannanoa,NC 28778 D. 828 296 4500 T 1 828 299 7043 F NORTH CAROLINA s Department of Environmental puali y Ms.Amy Moore May 18, 2022 Page 2 In both cases, a Certification Form with the date and time of submittal on the top of the form, signed by your facility's legally Responsible Official along with one copy of the supporting documentation, which includes calculations and emission factor references to demonstrate how emissions were calculated(show your work), must be postmarked to this Office by the same due date. Furthermore, if you are requesting information to be held as confidential, you must submit written justification as to how the information you have marked confidential should be held as such. This request must include the following: a. How the information meets the definition of"Trade Secret" per NCGS 132-1.2 and NCGS 66-152(3); b. How the information is not "Emissions Data" as defined in 40 CFR 2.301; c. How your facility would be affected if the information is disclosed; and d. How the information is protected at your facility. Only one copy of those pages which contain confidential information is required to be submitted. Additional information concerning confidential business information can be found at https•//files ncEov/ncdeq/Air%2OQuality/hermits/iiiemos/public records giver final.pdf. You are strongly encouraged to read the linked document prior to submitting confidential information to NC DAQ. A complete air permit renewal application must contain the completed FORM A and a completed air emissions inventory. Incomplete submittals will not be accepted and there will be no extensions. Facsimiles(faxes)will not be accepted as an original submittal. Facilities failing to comply with this requirement by the stated deadline are subject to enforcement action pursuant to NCGS § 143-215.114. If you submit any information via US mail, we strongly urge that you use "return receipt requested" (e.g. certified mail), so you have a record if there are any questions or a dispute regarding receipt of the submittal. You are encouraged to consider pollution prevention as a potential way to reduce emissions and possibly qualify your facility or emission unit(s)for permit exemption pursuant to 15A NCAC 2Q .0102. If you need assistance in identifying pollution prevention opportunities at your facility,you may contact the Division of Environmental Assistance and Customer Service(DEACS) at 1-877-623-6748 (http://deq.nc.�,-ov/about/divisions/environmental-assistance-customer-service). DEACS has experienced personnel that provide free, confidential pollution prevention opportunity assessments to help NC businesses and industries reduce air emissions and releases to other environmental media. For small businesses, an additional resource for assistance is the Small Business Assistance Program,toll free at 1-877-623-6748 (or their web site at littp•//deq nc �;ov/about/divisions/eiivironrnetital-assistance-customer-service). S incerely, Brendan G. Davey, P.E., Regional Supervisor Division of Air Quality,NCDEQ cc: James Hamrick, Caldwell Cabinets of NC, LLC