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HomeMy WebLinkAboutAQ_F_1800377_20211022_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office AIR QUALITY Certainteed Vinyl Operations NC Facility ID 1800377 Inspection Report County/FIPS: Catawba/035 Date: 10/21/2021 Facility Data Permit Data Certainteed Vinyl Operations Permit 06650/R13 2651 Penny Road Issued 10/9/2014 Claremont,NC 28610 Expires 9/30/2022 Lat: 35d 42.4062m Long: 8ld 9.5748m Class/Status Synthetic Minor SIC: 5033/Roofing,Siding And Insulation Permit Status Active NAICS: 42333/Roofing,Siding,and Insulation Material Merchant Wholesalers Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Brian Lane Michael Foster Brian Lane MACT Part 63: Subpart ZZZZ EHS Manager Plant Manager EHS Manager (828)459-8944 (828)459-3324 (828)459-8944 Compliance Data Comments: Inspection Date 10/21/2021 Inspector's Name Sandra Sherer Inspector's Signature: Sand to Shvte4 DIN Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: 10/22/2021 Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2013 7.07 --- --- 2.54 --- 7.07 318.00 2008 65.05 --- --- 13.79 --- 0.3300 87.99 *Highest HAP Emitted(in pounds) 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 Certainteed Vinyl Operations October 21,2021 Page -2— Type Action: X Full Compliance _Partial Compliance _Complaint Other: Evaluation Evaluation/Reinspection Investigation Data Date submitted for initial review 10/22/2021 _IBEAM WARNING/OB,NOD,NOV,NRE Tracking: X IBEAM Document X IBEAM Inspection,list date inspected X 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 10/1/2022 Directions: From MRO,travel I-77 north to I-40 west. Take exit 135 (Claremont),turn left onto North Oxford Street and then right onto Main Street(Hwy. 70). Travel approximately one mile and turn left onto Penny Road(at Claremont Industrial Park). The facility is located on the right at 2651 Penny Road. Safety Equipment: Safety glasses,hearing protection,hardhat,safety shoes,and a safety vest are required. Safety Issues: None noted. COVID-19 Information: The facility requires their employees and all visitors to wear a mask while in the building and practice social distancing,due to the COVID-19 virus. Lat/Lonz Coordinates: A review of the "Facilities Regulated by Air Quality" on the DAQ website 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 are needed in IBEAM. Email Contacts: IBEAM email contacts were verified with no changes required. 1. The purpose of this site visit was to conduct a compliance inspection while maintaining social distancing of six feet or more and wearing a mask,due to the corona virus.The facility requires the employees to wear masks during work hours, only allowing them to take them off to eat. This facility manufactures vinyl siding. The facility operates 24 hours a day, seven days a week. The facility employs approximately 178 full time employees. Mr. Brian Lane, EHS Manager, accompanied me during the inspection. 2. Facility Contact Information: During the inspection, I verified the facility contact information in IBEAM. 3. Compliance Histor. The facility was issued a Notice of Violation on March 25, 2014 for monitoring requirements. Certainteed Vinyl Operations October 21,2021 Page -3- 4. Observations of permitted air emission sources and control devices: Emission Emission Source Control Control System Source ID I Description System ID Description ES-1001 PVC resin vacuum FR-1001 filter receiver(183 railcar unloading system square feet of filter area). (25,000 pounds per hour maximum capacity) Observed. PVC powder is unloaded from railcars. The PVC resin vacuum system was operating at the time of inspection with no visible emissions. ES-1011 PVC storage silo(12,500 BV-1011 bin vent filter(184 pounds per hour square feet of filter area) maximum capacity) Observed. Once the PVC powder is unloaded from the railcars to the silo,it is transferred from the silos to the process. The silo vents to a bagfilter on top of the silo. The silo was being filled at the time of inspection with no visible emissions. ES-1012 PVC storage silo(12,500 BV-1012 bin vent filter(184 pounds per hour square feet of filter area) maximum capacity) Observed. Once the PVC powder is unloaded from the railcars to the silo,it is transferred from the silos to the process. The silo vents to a bagfilter on top of the silo. The silo was not being filled at the time of inspection. ES-1015a calcium carbonate silo BV-1015a bin vent filter(183 (20 tons per hour fill square feet of filter area) rate) Observed. The calcium carbonate silo is located near the railcar unloading area. The silo vents to a bagfilter on top of the silo. Calcium carbonate is unloaded from a truck to the silo. No calcium carbonate was being loaded to the silo at the time of the inspection. ES-1015b calcium carbonate BV-1015b bin vent filter(226 pneumatic conveyor(2 square feet of filter area) tons per hour maximum unloading rate) Observed. The calcium carbonate was being conveyed to the process at the time of inspection. I saw no visible emissions from the conveyor. ES-2001 vacuum resin conveying FR-2001 bagfilter(183 square feet system(19,500 pounds of filter area) per hour maximum capacity) Certainteed Vinyl Operations October 21,2021 Page -4- Emission Emission Source Control Control System Source ID Description System ID Description Observed. The vacuum resin conveying system is used to transfer PVC resin from the storage silos to the blending operations(heat and cool mixers). The resin conveyor was operating at the time of inspection with no visible emissions. ES-3001 vacuum compound FR-3011,FR-3012, twenty(20)bagfilters conveying system FR-3021,FR-3022, (ID Nos. FR-3011,FR- (51,000 pounds per hour FR-3031,FR-3032, 3012,FR-3021,FR- capacity)consisting of FR-3041,FR-3042, 3022,FR-3031,FR- twenty(20)vacuum FR-3051,FR-3052, 3032, FR-3041,FR- conveying lines FR-3062,FR-3072, 3042,FR-3051,FR- FR-3082,FR-3092, 3052,FR-3062,FR- FR-3102,FR-3061, 3072,FR-3082,FR- FR-3071,FR-3081, 3092, and FR-3102,FR- FR-3091,FR-3101 3 06 1,FR-3071,FR- 3081,FR-3091, and FR- 3101; 183.4 square feet of filter area, each) installed in parallel. Observed. Ten of the vacuum conveying lines, consisting of five stations with two lines per station was operating during the inspection. Each line has one bagfilter unit used to transport PVC compound from the storage silos to the vacuum receivers. The exhaust from the system is sent to a blower which then exhausts through a roof vent. I saw no visible emissions from this operation. ES-6001 cool mixer(24,000 FR-6001 bagfilter(183.4 square pounds per hour feet of filter area). maximum capacity) Observed. Blended compounds from the blending heat mixer are further processed in the cool mixers before being sent to the compound silos that are located inside the building. The process vents to a bagfilter located on top of the building. The cool mixer was operating at the time of inspection with no visible emissions. ES-6002 cool mixer(24,000 FR-6002 bagfilter(183.4 square pounds per hour feet of filter area). maximum capacity) Observed. This mixer is no longer being used by the facility and has been removed from facility property. This cool mixer will be added to the yellowsheet for removal from permit during the next permit renewal. ES-6003 blending heat mixer FR-6003 bagfilter(183.4 square (24,000 pounds per hour feet of filter area). maximum process rate) Observed. Blended compounds from the blending heat mixer are further processed in the cool mixers before being sent to the compound silos that are located inside the building. The process vents to a Certainteed Vinyl Operations October 21,2021 Page - 5— Emission Emission Source Control Control System Source ID Description System ID Description bagfilter located on top of the building. The blending heat mixer was operating at the time of inspection with no visible emissions. ES-7001 glue application line used in construction of N/A N/A cardboard boxes containing vinyl siding Observed. Water-based glue is stored in plastic totes. There is one(1)hand-spraying line and three (3) automatic spraying lines. The glue application line was operating at the time of inspection with odorous emissions. ES-8001 barcode labeling system including fifteen(15)ink 'et print heads installed N/A on ten(10) extrusion lines Observed. The barcode system operates intermittently and is used to print product numbers and information regarding production on the finished product. Currently only ten ink jet print heads are installed on six(6) extrusion lines. The barcode system was operating at the time of inspection with no odorous emissions. ES-8002 PVC grinding operation FR-8002 bagfilter(1,530 square (3,000 pounds per hour feet of filter area). maximum process rate) Observed. Collected waste from the grinding of rejected siding is ground up and recycled. The process vents to a bagfilter located on top of the building. The PVC grinding operation was operating at the time of inspection with no visible emissions. 5. Observations of insignificant air emission sources and control devices listed on the current permit: Source PTAPs? ource of Source of Title V Pollutants? IES-5001 -extruder process consisting of ten(10) Yes Yes extrusion lines (two extruders per line) Observed. The extruders are used to make the final product where the PVC compound is sent through a chill roller, pre-former roll, water bath and a cutter/stacker. After exiting the extruder process, the vinyl siding is placed into cardboard boxes and sent to the storage area. This process was operating during the inspection with no problems noted. I-PUMP -diesel-fired fire pump(220 hp) subject to Yes Yes MACT Subpart ZZZZ Certainteed Vinyl Operations October 21,2021 Page -6— Observed. The fire pump was not in operation at the time of inspection. The hour meter read 339.5 hours at the time of the inspection. The facility ran the diesel-fired fire pump 27.5 hours since the previous inspection conducted on October 20,2020. I-TOWER-cooling tower No FYes Observed. The cooling tower was operating during the inspection with no problems noted. 6. Observations of air emission sources and control devices not listed on the current permit: a. None. 7. Compliance with specific permit conditions and limitations: a. Condition A.2. requires the facility to submit the permit renewal application including an emission inventory at least 90 days prior to the expiration date of the Air Permit. Observed. A new air permit was issued on October 9, 2014 due to expire on September 30,2022. Compliance is indicated for this condition. b. Condition A.3. 15A NCAC 2D .0515 "Particulates from Miscellaneous Industrial Processes"particulate matter emissions shall not exceed allowable emission rates. Observed. There are no monitoring, recordkeeping or reporting requirements with this stipulation. The allowable emission rates from this facility are not being exceeded. Compliance with this stipulation was determined during the permit application process. C. Condition A.4. 15A NCAC 2D .0521, "Control of Visible Emissions". The facility is limited to 20 percent opacity. Observed. No visible emissions were observed at the facility. Compliance with this stipulation is indicated. d. Condition A.5. 15A NCAC 2D .0535. 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 review of DAQ files and conversation with Mr. Lane, no excess emissions have occurred at the facility in several years. Compliance with this stipulation is indicated. e. Condition A.6. 15A NCAC 2D .0540 "Particulates from Fugitive Dust Control 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. Observed. There have been no dust complaints received by the MRO concerning the facility and no fugitive dust emissions were observed at the time of this inspection. Compliance with this condition is indicated. Certainteed Vinyl Operations October 21,2021 Page -7— f. Condition A.7. 15A NCAC 2D .0958(c) "Work Practices for Sources of Volatile Organic Compounds". Store all VOC-containing material in closed containers when not in use,and clean spills and equipment properly. This condition also requires the facility to comply with work practices for solvents. Observed. VOCs are only emitted in the bar code labeling system and the glue applications. The glue is contained in enclosed plastic totes and printing ink and MEK are stored in a locked cabinet. There are no solvents used at the facility. Compliance with this condition is indicated. g. Condition A.8 Federal and State Rules Applicable to Sources Exempted from Air Permitting Requirements-The Permittee shall comply with all applicable provisions including operating restrictions,work practices,monitoring,recordkeeping, and reporting requirements as promulgated in 40 CFR 63, Subpart ZZZZ. Each subject engine shall be operated and maintained in a manner consistent with safety and good air pollution control practices for minimizing emissions. Each subject engine may be operated for 50 hours per calendar year for non-emergency situations. The 50 hours of operation in non-emergency use are counted as part of the 100 hour per calendar year for maintenance and testing. The following requirements apply: - change oil and filters every 500 hours of operation or annually, whichever comes first, or utilize an oil analysis program; - inspect air cleaners every 1,000 hours of operation or annually, whichever comes first; - inspect all hoses and belts every 500 hours of operation or annually, whichever comes first,and replace as necessary; - and minimize time spent at idle and minimize start-ups to a period needed for appropriate and safe loading not to exceed 30 minutes; - use of diesel fuel with a sulfur content of 15 ppm maximum; and - install non-resettable hour meter. Observed. The facility has a diesel fire pump for emergency purposes which runs on low- sulfur diesel fuel. The non-resettable hour meter read 339.0 during the time of the inspection. Since the last inspection on October 20, 2020, the engine has run 27.5 hours. I reviewed records of the last two tune-ups that were conducted on May 19,2020 and May 4,2021. Compliance was indicated. h. Condition A.9. LIMITATION TO AVOID 15A NCAC 2Q .501 Pursuant to 15A NCAC 2Q .0315 "Synthetic Minor Facilities,"to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of Section and Requirement for a Permit," as requested by the Permittee, facility-wide emissions shall be less than the following: Certainteed Vinyl Operations October 21,2021 Page - 8— �ollutant� Emission Limit (Tons per consecutive 12-month period) PM10 1 100 a. Inspection and Maintenance Requirements- i. Bagfilter Requirements-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 regulated limits,the Permittee shall perform periodic inspections and maintenance(I&M) as recommended by the manufacturer. In addition,the Permittee shall perform an annual(for each 12 month period following the initial inspection)internal inspection of each bagfilter system. b. Recordkeeping Requirements i. A log book(in written or electronic format) shall be kept on site for each control device and made available to Division of Air Quality personnel upon request. The Permittee shall record all inspection,maintenance and monitoring requirements listed above in the log book.Any variance from the manufacturer's recommendations shall be investigated with corrections made and date of actions recorded in the log book. Observed. The facility is currently conducting a minimum of annual internal baghouse inspections. I reviewed baghouse inspection records during the inspection that showed the annual inspection dates are as follows: Emission Emission Source Control Control System Last completed inspections Source ID Description System ID Description ES-1001 PVC resin FR-1001 filter receiver 4/21/20 10/30/20,5/15/21 vacuum railcar (183 square feet unloading system of filter area) (25,000 pounds per hour maximum capacity) ES-1011 PVC storage silo BV-1011 bin vent filter 4/15/20 12/10/20, 10/18/21 (12,500 pounds (184 square feet per hour of filter area) maximum capacity) ES-1012 PVC storage silo BV-1012 bin vent filter 4/15/20 12/10/20, 10/18/21 (12,500 pounds (184 square feet per hour of filter area) maximum capacity) ES-1015a calcium carbonate BV-1015a bin vent filter 9/22/20 10/18/21,3/26/21 silo(20 tons per (183 square feet hour fill rate) of filter area) Certainteed Vinyl Operations October 21,2021 Page -9- Emission Emission Source Control Control System Last completed inspections Source ID Description System ID Description ES-1015b calcium carbonate BV-1015b bin vent filter 9/22/20 5/8/21 pneumatic (226 square feet conveyor(2 tons of filter area) per hour maximum unloading rate) ES-2001 vacuum resin FR-2001 bagfilter(183 4/20/20 10/30/20,5/8/21 conveying system square feet of (19,500 pounds filter area) per hour maximum capacity) ES-3001 vacuum FR-3011,FR- twenty(20) See below compound 3012,FR-3021, bagfilters(ID conveying system FR-3022,FR- Nos.FR-3011, (51,000 pounds 3031,FR-3032, FR-3012,FR- per hour capacity) FR-3041,FR- 3021,FR-3022, consisting of 3042,FR-3051, FR-3031,FR- seventeen(17) FR-3052,FR- 3032,FR-3041, vacuum 3062,FR-3072, FR-3042,FR- conveying lines FR-3082,FR- 3051,FR-3052, 3092,FR-3102, FR-3061,FR- FR-3061,FR- 3062,FR-3071, 3071,FR-3081, FR-3072,FR- FR-3091,FR- 3081,FR-3082, 3101 FR-3092,and FR- 3102,FR-3081, FR-3091,and FR- 3101; 183.4 square feet of filter area,each) installed in parallel There are two bagfilters per line. Line 1,2 and 4 are not in use. Line 3 Units 3031 and 3032 4/22/20, 1/5/21,and 5/18/21 Line 4 Units 3041 and 3042 4/21/20,and 5/16/21 (the facility keeps this line ready as a standby unit) Line 5 Units 3051 and 3052 9/22/20 and 4/2/21 Line 6 Units 3061 and 3062 5/11/20 and 4/1/21 Line 7 Units 3071 and 3072 4/22/20, 10/16/20 and 4/2/21 Line 8 Units 3081 and 3082 4/27/20 and 4/8/21 Line 9 Units 3091 and 3092 9/22/20 and 9/4/21 Line10 Units 3101 and 3102 4/22/20,5/20/21 and 1/5/21 ES-6001 cool mixer FR-6001 bagfilter(183.4 5/4/20 5/11/21 (24,000 pounds square feet of per hour filter area) maximum capacity) Certainteed Vinyl Operations October 21,2021 Page - 10— Emission Emission Source Control Control System Last completed inspections Source ID Description System ID Description ES-6002 cool mixer FR-6002 bagfilter(183.4 N/A N/A (24,000 pounds square feet of (Has been per hour filter area) removed from maximum facility) capacity) ES-6003 blending heat FR-6003 bagfilter(183.4 7/10/20 1/5/21,8/27/21 mixer(24,000 square feet of pounds per hour filter area) maximum process rate) ES-8002 PVC grinding FR-8002 bagfilter(1,530 6/5/20 5/20/21 operation(3,000 square feet of pounds per hour filter area) maximum process rate) i. Condition A10. 15A NCAC 2Q .0711 "Emission Rates Requiring a Permit." The facility's use of MEK is limited to 78 pounds per day or 22.4 pounds per hour. Observed. The facility is keeping MEK usage data. From Jan 1 through December 31, 2020 the facility used 33.8 liters of MEK (74.2 lbs.), and operated the printers approximately 200 days, 24 hours per day, which calculates into the facility using approximately 0.371 lbs. of MEK per day or 0.015 lbs. of MEK per hour. Compliance is indicated for this stipulation. 8. NSPS/NESHAP Review The facility has a diesel fire pump that is subject to NESHAP 4Z. The facility has no boilers or gasoline storage tanks that would be subject to NESHAP 6J or NESHAP 6C,respectively. 9. Summary of changes needed to the current permit: Remove emission source (ES-6003) "cool mixer" from permit. The facility only uses one cool mixer(ES-6001) and the other one has been removed from the site. This change was added to the facility's yellowsheet. 10. Compliance assistance offered during the h�pection: None. 11. Section 112(r) qpplicabilitX: 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: Certainteed Vinyl Operations October 21,2021 Page - 11 — Based on my observations,this facility appeared to be in compliance with the applicable air quality regulations at the time of the inspection. SLS:lms c: MRO File https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/CATA)"A/00377/INSPECT_20211021.docx