HomeMy WebLinkAboutAQ_F_0200099_20221215_PRMT_CmbPrmtFile_RESCIND ROY COOPER � �
Governor
ELIZABETH S.BISER
Seovta,y
MICHAEL A.ABRACZINSKAS NORTH CAROLINA
Director Environmental Qualify
December 15, 2022
Mr. Michael Harris
President
Harris Manufacturing, Inc.
1871 Friendship Church Road
Taylorsville,NC 28681
SUBJECT: Rescission Request
Application No. 0200099.22A
Harris Manufacturing, Inc.
Facility ID: 0200099, Taylorsville,Alexander County
Permit Class: Small
Permit No. 10074RO I
Dear Mr. Harris:
The Division of Air Quality has reviewed your letter and supporting documentation received
December 6, 2022 requesting rescission of Permit No. 10074RO L
Based on this information, the facility does qualify for exemption from permitting since the facility
is currently classified as "small' and the facility-wide actual emissions of particulate matter
(PM10), sulfur dioxide, nitrogen oxides, volatile organic compounds,carbon monoxide, hazardous
air pollutants (HAP), and toxic air pollutants (TAP), from previous years, each has been less than
five (5) tons per year and the total actual aggregate emissions of these pollutants have been less than
10 tons per year. The letter also indicated that there are no future plans to make any changes that
would increase emissions above these exemption thresholds.
Therefore, in accordance with your request,Air Quality Permit No. 10074ROI is hereby rescinded,
effective the date of this letter. It should be noted that this exemption from permitting does not
exempt Harris Manufacturing, Inc. from complying with the applicable emission control standards.
North Carolina Department of Environmental Quality I Division of Air Quality
NORTH Cnna.,:NA - Mooresville Regional Office 1610 East Center Avenue,Suite 3011 Mooresville,NC 28115
DWrWOMof€mriMMMflmm 'pry 704.663.1699 T 1704.663.6040 F
Mr. Michael Harris
December 15, 2022
Page 2
Furthermore, should you decide to modify the processes such that the result is an increase of
emissions above the emission thresholds given above, an Air Quality Permit may be required and
Harris Manufacturing, Inc. should contact this Regional Office prior to such actions for a permit or
registration applicability determination.
This exemption from the permitting requirement is based upon your statement that this facility has
been and will be operated under the threshold levels as outlined in the Regulation NCAC 2Q
.0102(d). Please be advised that the operation of any air pollution emission sources which results in
increased emissions in excess of the threshold levels specified in 15ANCAC 2Q.0102(d)without an
Air Quality Permit is a violation of 15A NCAC 2Q.0101, "Required Air Quality Permits." If this
facility is required to obtain an Air Quality permit in the future because of increased emissions, each
day of operation of the emission sources without an Air Quality Permit represents a separate
violation. Such violations may be subject to enforcement action pursuant to NCGS 143-215.114A.
Please be aware that even though your facility may no longer be subject to permitting requirements,
the operations must still comply with all applicable state and federal laws and regulations. The
attached Facility Compliance Tracking Checklist may be of help to you in verifying you remain in
compliance with certain federal and state regulations. It may also aid in determining if you remain
below the emissions threshold. You may use this checklist at your discretion as it is intended to be
used as a guidance document only. Furthermore, it is DAQ's intent to periodically conduct
compliance assurance visits at exempt facilities. If you have any questions with reference to the
above matter,please do not hesitate to contact Jennifer Manning at 704-235-2224.
Sincerely,
W r
Melinda Wolanin,Regional Supervisor
Division of Air Quality,NCDEQ
Enclosure
JAM
c: Laserfiche
https://nceonnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEYANDER/00099/ROl RESCIND 20221215.docx
Facility Compliance Tracking Checklist revised 06-16-2016
Calendar Year - -
Are calendar year emissions below exemption threshold? - 0 Yes 01 No
Annual Throughput(quantity of materials made or processed)
O.e.concrete,,asphalt,�cotton,vtaodwastegeneretc-)
v
� ate ,etc_
Units(i.e.tons,pounds,bales,etc.)
Quantity of Fuels Comhusted:
Natural Gas
No.2fuel oil Sulfur Content gallons
LPG _ gallons
Wood tons
Link to NSPS and NESHAP rule guidance;
http,//deq.nc.gov/about/divisions/air-quality/air-quality-per ts/`specific-permit-conditions-re €ilatory-gLiide
NSPS Dc subject boilers: -
Does fuel oil contain>0.5°%sulfur? _
Was report submitted semi-annually? Yes No N/A
13'Yes No : 0 N/A
Did you conduct timely opacity monitoring for>30rn Btu boilers on fuel oil? )✓.;Yes 0 No N/A
NESHAP si subject boilers:
:Date of last biennial/5 yr tune-up?
;Compliance certification on site 0 Yes 0 No 0 N/A
NESHAP 4Z f NSPS 41 NSPS 4!subject engines: _ -
New emergency and non-emergency engines;
Certificate of Conformity on situ lam'Yes 0,No �N/A
Does fuel oil contain>0.00151/'o sulfur?° Yes No 10 N/A
'Existing erTiergencyengines.
Date of last oil change/analysis,belt/hose/filter/plugs inspection&maintenance? O N/A
Number of hours run for non-emergency(includes testing&maintenance)? 0 N/A -_
Existing non-emergency engines using a Diesel Oxidation Catalyst(DEC),
Date of last compliance source test? � N/A
Notice of testing submitted?60 clays prior to testing O Yes O No 0 N/q
Did source test show compliance? _ _. 0 Yes 0 No . 0 N/A
Does fuel oil contain>0.0015%sulfur? 0 Yes 01 No . OVA
Is temperature continuously recorded and tracked as a 4 hour rolling average? 'Yes U. No , D N/A -
is pressure drop recorded monthly? l YesNo �lN/A
Facility wide Applicability:
Visible emissions>20°i from any sources/devices; 0 Yes 10 No
Any signs of dust leaving property or any complaints' L-Yes No
Any new sources or control devices added? ;Yes O'No ,
Were they evaluated for permitting - _ 01`Yes O No
Inspection&Maintenance on control devices - O Yes U,No O N/A
"*The checklist is being provided only as a guidance document.Complying with this checklist does not ensure compliance with
the regulations and does not absolve you from ensuring your€acuity is in compnance with all appropriate air quality regulations
i
ENV p DEPARTMENT OF
NMENTAL QUALITY
RECEIVED
Regional Supervisor DEC 0 6 2022
NC."ill Cal, Division of Air Quality
VILLE RE
Mooresville Regional Office MOpRES ORESO GIONAL OFFICE
Cale)burst Center A ettutc:,Suite' 301 N OF AIR QUALITY
Mooresville,Tit::28115
Sullied. Permit Rescission Request
Harris Mailtufacturin ,file,
`ra lorsville.NC
Alexander County
Facility 10:0200099
Permit No. 10074ROI
Dear Ms.NVolanin:
Our tacility would life to request rescission of our Air{,duality Permit clue•-.to the f<let that our actual
emissions of particulate matter([' t ,),sulfur dioxide.nitucr en oxides.volatile organic compounds,
carbon monoxide,hazardous air pollutants.and toxic air pollutants are each less than five(a)toils per
year and total aggregate ate emissions are less than 10 touts per year.We have examined our production
history over the last five years und have,assessed our future production demand.Our facility is confident
that emission,,mill reutuain below the exemption threshold since our potential emissions after controls,as
calculated ulated in the review for RO 1.are tuuder the thresholds.As such the actu l emissions will lie well
underthe threshold limits.
If you have any quest ions with reference to the above chatter,please do not hesitate to contact nee at(828)
632-4889 and harri,ma t fact; r bell'onillmct.
�inc;crel}'
Michael I-larris
president
https://neconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00099/ROl_RESCRE V.docx
NORTH CAROLINA DIVISION OF Region: Mooresville Regional Office
AIR QUALITY County: Alexander
Application Review NC Facility ID: 0200099
Inspector's Name: Ryan Mills
Date of Last Inspection: 05/19/2022
Compliance Code: 3/Compliance-inspection
Facility Data Permit Applicability(this application only)
Applicant(Facility's Name): Harris Manufacturing,Inc. SIP:Yes
NSPS: No
Facility Address: NESHAP:No
Harris Manufacturing, Inc. PSD: No
1871 Friendship Church Road PSD Avoidance: No
Taylorsville,NC 28681 NC Toxics: N/A
112(r): No
SIC:2512/Upholstered Household Furniture Other: N/A
NAICS: 337121/Upholstered Household Furniture Manufacturing
Facility Classification: Before: Small After: Exempt
Fee Classification:Before: Small After: N/A
Contact Data Application Data
Facility Contact Authorized Contact Technical Contact Application Number: 0200099.22A
Michael Harris Michael Harris Michael Harris Date Received: 12/06/2022
President President President Application Type: Rescission Request
(828)632-4889 (828)632-4889 (828)632-4889 Application Schedule: Rescission
1871 Friendship Church 1871 Friendship Church 1871 Friendship Church Existing Permit Data
Road Road Road Existing Permit Number: 10074/R01
Existing Permit Issue Date: 02/24/2015
NC 28681 Taylorsville,NC 28681 Taylorsville,NC 28681 Taylorsville, Y Existing Permit Expiration Date: 01/31/2023
Review Engineer: Jennifer Manning Comments/Recommendations:
Review Engin er's Signature: Date i ,b Issue:Rescission Letter
A
1. PURPOSE OF APPLICATION:
The facility submitted a request to rescind Air Permit No. 10074ROI due to actual and future
projected actual PM10, S02, NOx, VOC, CO, HAPs and TAPs emissions each being less than five
tons per year and total aggregate of these emissions being less than 10 tons per year. The facility
qualifies for this exemption since they are not required to have a permit pursuant to 15A NCAC 2Q
.0500 (Title V Procedures).
2. APPLICATION CHRONOLOGY:
The application was received on December 6, 2022, and was considered complete.
Permit review for rescission by exemption
Page 2
3. DESCRIPTION OF BUSINESS - This facility manufactures wooden furniture frames. The table
below lists emissions sources listed on the facility's current permit.
Permitted:
Emission Emission Source Control Control System
Source ID Description System ID Description
WW-1 1600dworking operation CD-1 bagfilter(3,060 square
Efeet of filter area)
Exempt:
Source
IES Dip dipping operation
- ..... �..:..
4. APPLICABLE REGULATIONS - The facility is subject to the following North Carolina
Administrative Code(NCAC)Title 15A regulations.
® 15A NCAC 2D .0512,"Particulates from Wood Products Finishing Plants"
® 15A NCAC 2D .0521, "Control of Visible Emissions"
® 15A NCAC 2D .0535,"Excess Emissions Reporting and Malfunctions"
® 15A NCAC 2D .0540, "Particulates from Fugitive Dust Emission Sources"
5. FACILITY-WIDE EMISSIONS—
The facility did not provide any production data or emissions calculations with the rescission request.
However,based on the last permit review(RO1),the facility potential emissions after controls are all
under 5 tpy as follows:
Pollutant Potential Emissions Potential Emissions
After Controls/Limitations } Before Controls/Limitations(tpy)
TSP 0.42 416.28
PM10 0.30 59.56
SO2 0 0
NO x 0 0
VOC 1.14 1.14
CO 0 0
Highest HAP 0.15 0.15
(toluene)
Total HAP 0.29 0.29
As such,the actual emissions are certainly under the exemption thresholds. In addition,the facility
stated in the rescission request letter that their emissions will remain below the exemption thresholds
in the future.
Permit review for rescission by exemption
Page 3
6. COMPLIANCE - The facility was last inspected for permit compliance by Ryan Mills on May 19,
2022, and the facility was determined to be in violation with Air Quality standards and regulations at
the time of the inspection for not maintaining a logbook of the inspection and maintenance on the
bagfilter. They were issued a Notice of Violation on May 26, 2022. In addition, the facility had
received a Notice of Deficiency dated July 19, 2019,which was also for not maintaining a logbook of
the inspection and maintenance on the bagfilter. It should be noted that there did not appear to be any
excess emissions from poor bagfilter maintenance. There have been no other issues in the last 5 years.
7. RECOMMENDATION-Rescind Permit No. 10074RO1.