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HomeMy WebLinkAboutAQ_F_0200034_20220127_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office AIR QUALITY Hancock&Moore,LLC dba Hancock&Moore Plant 2 Inspection Report NC Facility ID 0200034 Date: 01/26/2022 County/FIPS:Alexander/003 Facility Data Permit Data Hancock&Moore,LLC dba Hancock&Moore Plant 2 Permit 02757/R13 165 Matheson Park Avenue Issued 12/31/2015 Taylorsville,NC 28681 Expires 6/30/2023 Lat: 35d 54.9186m Long: 8ld 10.5594m Class/Status Small SIC: 2512/Upholstered Household Furniture Permit Status Active NAICS: 337121 /Upholstered Household Furniture Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Junior Matheson Junior Matheson Dennis Tart MACT Part 63: Subpart 6J Facility Supervisor Facility Supervisor Environmental Engineer (828)495-8235 (828)495-8235 (828)326-8376 Compliance Data Comments: Inspection Date 01/26/2022 Inspector's Name Karyn Kurek Inspector's Signature: K c ynl K,l w'ekl Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: 1/27/2022 Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2014 15.88 0.0500 0.9300 0.0300 1.14 11.74 71.90 2009 9.30 0.0300 0.5000 0.0200 0.6100 6.87 92.72 *Highest HAP Emitted(in pounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 06/04/2021 NOV 2D.1404 Recordkeeping:Reporting: Monitoring: 06/10/2021 Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested Hancock&Moore,LLC dba Hancock&Moore Plant 2 January 26,2022 Page 2 Type Action: X Full Compliance _Partial Compliance _Complaint Other: Evaluation Evaluation/Reinspection Investigation Data Date submitted for initial review 01/27/2022 X IBEAM WARNING/OB,NOD,NOV,NRE Tracking: X IBEAM Document X IBEAM Inspection,list date inspected _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 01/01/2024 Directions: From MRO,travel I-77 north to 1-40 west,take exit 148 and travel west on Hwy. 64 to Taylorsville. From Highway 64 take the Highway 16 North exit and travel approximately 1 mile and turn right onto Matheson Park Avenue. The facility is the white building. The entrance to the facility office is just right of the address numbers"165"on the building. Safety Equipment: Safety glasses, safety shoes, and ear protection are required. Safety Issues: None noted. Lat/Lonir A review of the facility's coordinates on"Maps of DAQ Regulated Facilities"indicates the facility's latitude and longitude coordinates are accurate but are not locked in IBEAM. Email Contacts: Facility contacts were reviewed and updated in IBEAM. Covid: Masks are required regardless of vaccination status. 1. The purpose of this site visit was to conduct a routine air quality inspection. This facility used to manufacture wooden furniture frames. The facility is no longer operating,they had plans last year to sell the business, however they are no longer selling it. There are only three (3) employees located at this site. Mr. Dennis Tart, Environmental Engineer, accompanied me during the inspection. 2. Facility Contact Information: Facility contacts were reviewed and updated in IBEAM. 3. Compliance history file review: On June 4,2021,the facility received a NOV for failing to conduct annual inspections on the wood working operations control devices. Hancock&Moore,LLC dba Hancock&Moore Plant 2 January 26,2022 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 1 (NESHAP) wood-fired boiler(1.6 million Btu per hour N/A N/A maximum heat input) Observed.The listed wood fired boiler was removed and replaced with a natural gas burning unit.A letter postmarked March 1, 2016, was received by this office from Hancock & Moore stating these changes. The new unit is a Cleaver Brooks, model number CB 200-236-150 and Serial No OL098738. This 9,875,125 Btu/hr unit was built in 1999,but it was put into service 9/21/2010.The boiler has an operational max psi rating of 150. These changes have been listed on the electronic yellow-sheet. The natural gas boiler was in operation at the time of this inspection with no issues noted. Emission Emission Source Control Control System Source ID Description System ID I Description W-1 woodworking operation CD-2 cyclone(114 inches in diameter) Observed. These were not in operation at the time of inspection. Emission Emission Source Control Control System Source ID Description System ID Description W-2 woodworking operation CD-3 cyclone(114 inches in diameter) Observed.These were not in operation at the time of inspection. Emission Emission Source Control Control System Source ID Description System ID Description W-3 woodworking operation CD-4,CD-5, CD-6 cyclone(40 inches in diameter,ID No. CD-4), dynavane(three single cells,ID No. CD-5), and bagfilter(85 square feet of filter area,ID No. CD-6),installed in series Observed.These were not in operation at the time of inspection. 5. Observations of insignificant air emission sources and control devices: Source Exemption Source of Source of Title V Regulation FTAPS? Pollutants? IES-1 -wood gluing F2Q .0102 (c)(2)(D)(i) No No operation Observed.No wood gluing was occurring at the time of this inspection. Hancock&Moore,LLC dba Hancock&Moore Plant 2 January 26,2022 Page 4 6. Observations of air emission sources and control devices not listed on the current permit: a. A new gas-fired boiler was installed at the beginning of 2016. The new unit is a Cleaver Brooks,model number CB 200-236-150 and Serial No OL098738. This 9,875,125 Btu/hr unit was built in 1999,but it was put into service 9/21/2010. The boiler has an operational max psi rating of 150. The unit was observed in operation without any visible emissions. A letter postmarked March 1, 2016, was received by this office from Hancock& Moore stating these changes. These changes have been listed on the electronic yellow-sheet. 7. Compliance with specific permit conditions and limitations: a. Condition A.2. 15A NCAC 2D .0202 "Permit Renewal and Emission Inventory Requirement". The Permittee, at least 90 days prior to the expiration date of this permit, shall request permit renewal by letter. The report shall be submitted to the Regional Supervisor,DAQ and shall document air pollutants emitted for the 2022 calendar year. Observed: The current permit does not expire until June 30, 2023. Compliance is indicated. b. Condition A.3. 15A NCAC 2D .0504 "Particulates from Wood Burning Indirect Heat Exchangers".Particulate matter emissions from the wood burning indirect heat exchangers shall not exceed the allowable emission rate of 1.05 lbs/million Btu. Observed:This condition no longer applies,since the wood fired boiler has been removed. This change has been noted on the yellow sheet by the previous inspector. C. Condition A.4. 15A NCAC 2D .0512 "Particulates from Wood Products Finishing Plants". Permittee shall not discharge particulate matter and shall provide adequate duct work and properly designed collectors. Observed: The dust collecting systems were not in operation at the time of the inspection. The equipment appeared to be in good condition. Compliance is indicated. d. Condition A.S. 15A NCAC 2D .0516 "Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the combustion sources shall not exceed 2.3 pounds per million Btu heat input. Observed: The wood fired boiler(ID No. 1)is the only source on the permitted equipment list subject to this regulation. However,that boiler is no longer located at the facility and should be removed from the equipment list during the next permit revision.In addition,the facility has been operating a natural gas fired boiler since 2016(9.88 million Btu per hour maximum heat input rating),which will be added to the exempt list of sources during the next permit revision. Per MRO memo"21) .0516 analysis"dated 04/10/97,compliance with the sulfur limit is assumed for natural gas fired sources.Although this boiler is subject to 02D .0516, conditions that apply only to exempt sources are not listed in the permit. Therefore,this condition should be removed from the permit when the wood fired boiler is removed from the equipment list. Hancock&Moore,LLC dba Hancock&Moore Plant 2 January 26,2022 Page 5 e. Condition A.6. 15A NCAC 2D .0521 "Control of Visible Emissions".Visible emissions from woodworking operation (ID No. W-1), woodworking operation (ID No. W-2), and woodworking operation(ID No. W-3) shall not be more than 20 percent opacity. Observed: The facility is not operating; therefore, no visible emissions were observed during the inspection. Compliance is indicated. £ Condition A.7. 15A NCAC 2D .0521 "Control of Visible Emissions". Visible emissions from wood-fired boiler(ID No. 1) shall not be more than 40 percent opacity. Observed: The wood fired boiler is no longer in operation at the facility. This condition no longer applies. g. Condition A.8. 15A NCAC 2D .0535 "Notification Requirement". 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:The facility is not operating;therefore,no excess emissions have occurred since the last inspection. Compliance is indicated. h. Condition A.9. 15A NCAC 2D.0540"Particulates from Fugitive Dust Emission 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: The facility is not operating; therefore, no fugitive dust emissions were observed during the inspection. Compliance is indicated. i. Condition A.10. 15A NCAC 2D .0611 "Cyclone Requirements" To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory limits,the Permittee shall perform an annual inspection of the systems. The results of all inspections and any variance from the manufacturer's recommendations or from those given in this permit shall be investigated with corrections made and dates of actions recorded in logbooks. Records of all maintenance activities shall be recorded in the logbook. The logbooks shall be kept on-site and made available to DAQ personnel upon request. Observed:The facility is not operating.The most recent recorded inspection of the cyclone systems was June 7, 2021, and January 25, 2022 (previously November 19, 2018). The facility has not operated since October/November 2021. Compliance with this stipulation is indicated. j. Condition A.11. 15A NCAC 2D .0611 "Fabric Filter Requirements" To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory limits,the Permittee shall perform an annual internal inspection of the systems. The results of all inspections and any variance from the manufacturer's recommendations or from those given in this permit shall be investigated with corrections made and dates of actions recorded in logbooks. Records of all maintenance activities shall be recorded in the logbook. The logbooks shall be kept on-site and made available to DAQ personnel upon request. Hancock&Moore,LLC dba Hancock&Moore Plant 2 January 26,2022 Page 6 Observed: The facility is not operating. The most recent inspection of the fabric filter systems was June 7, 2021, and January 25, 2022 (previously November 19, 2018). The facility has not operated since October/November 2021. Compliance with this stipulation is indicated. k. Condition A.12. 15A NCAC 2D .0611 "Dynavane Requirements" To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory limits,the Permittee shall perform an annual internal inspection of the systems. The results of all inspections and any variance from the manufacturer's recommendations or from those given in this permit shall be investigated with corrections made and dates of actions recorded in logbooks. Records of all maintenance activities shall be recorded in the logbook. The logbooks shall be kept on-site and made available to DAQ personnel upon request. Observed: The facility is not operating. The most recent inspection of the dynavane systems was June 7, 2021, and January 25, 2022 (previously November 19, 2018). The facility has not operated since October/November 2021. Compliance with this stipulation is indicated. 1. Condition A.13. 15A NCAC 2D .IIII "GENERALLY AVAILABLE CONTROL TECHNOLOGY" For the wood-fired boiler (ID No. 1), the Permittee shall comply with all applicable provisions,including the notification,testing, and monitoring requirements. Observed: The wood fired boiler is no longer at the facility,therefore,this condition no longer applies. 8. NSPS/NESHAP Review There are no generators,fire pump engines, or gasoline storage tanks at the facility. 9. Summary of changes needed to the current permit: The facility is in the process of closure and might be sold before the next inspection. If sold, the facility would require an ownership change. The permit conditions concerning the wood fired boiler should be removed from the permit since the boiler is no longer onsite. 10. Compliance assistance offered duringthe hpection: The current permit expires June 30,2025.Mr.Dennis Tart and I discussed that a renewal letter will be sent to the facility prior to expiration. 11. Section 112(r)applicability: 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. Hancock&Moore,LLC dba Hancock&Moore Plant 2 January 26,2022 Page 7 12. Compliance determination: Based on my observations,this facility appeared to be in compliance with the applicable air quality regulations at the time of the inspection. KAK:lms c: MRO File https://neconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00034/INSPECT 20220126.doex