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HomeMy WebLinkAboutAQ_F_0200030_20220414_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office AIR QUALITY Piedmont Wood Products,Inc. NC Facility ID 0200030 Inspection Report County/FIPS:Alexander/003 Date: 04/14/2022 Facility Data Permit Data Piedmont Wood Products,Inc. Permit 05786/R09 1924 Black Oak Ridge Road Issued 11/26/2014 Taylorsville,NC 28681 Expires 10/31/2022 Lat: 35d 56.6880m Long: 8ld 9.4440m Class/Status Small SIC: 2426/Hardwood Dimension&Flooring Permit Status Active NAICS: 321912/Cut Stock,Resawing Lumber,and Planing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Martha Reese Martha Reese Martha Reese MACT Part 63: Subpart 6J President President President (828)632-4077 (828)632-4077 (828)632-4077 Compliance Data Comments: Inspection Date 04/14/2022 Inspector's Signature: x#" e Atiffi J993t Inspector's Name Ryan Mills Operating Status Operating Date of Signature:April 18,2022 Compliance Status Compliance-inspection Action Code FCE Inspection Result Violation Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2013 0.0400 0.0100 0.0100 --- --- 0.0300 0.0960 2008 0.0100 0.0600 0.0200 --- --- 0.0000 0.1400 *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 Piedmont Wood Products,Inc. April 14, 2022 Page -2— Type Action: X Full Compliance _Partial Compliance _Complaint Other: Evaluation Evaluation/Reinspection Investigation Data Tracking: Date submitted for initial review 04/18/2022 _IBEAM WARNING/OB,NOD,NOV,NRE 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 4/l/2024 Directions: From Mooresville travel I-77 North,take I-40 West,take exit 148,turn right onto Hwy. 64 West,travel approximately 10 miles to Taylorsville,turn right onto Adams Pond Lane,turn left onto Hwy. 90 (Main Ave),turn right onto Main Ave. Drive NE(Linneys Mt. Road),turn right onto Black Oak Ridge Road, travel approximately three miles,Piedmont Wood Products is on the right just before Jay Burke Road. You will go in the door that is on the left side of the building as you are looking at it. When you walk in you will be walking into the breakroom. Mr. Coffey's office is the second door on the right once you are inside the building. Safety Equipment: Safety glasses are required,and steel toe shoes are recommended for an inspection at this facility. Safety Issues• Watch for stacked lumber that could be sticking out into walkways and aisles. Also,watch for tractor trailer traffic. Lat/Lon2 Coordinates: A review of the"Map of Regulated AQ Facilities"on the DAQ web site indicated 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 of this facility are needed in IBEAM. The coordinates are locked in IBeam. Email Contacts: Ms. Reese's email address was updated in IBEAM. 1. The purpose of this site visit was to conduct a routine air quality inspection. This facility manufactures wooden furniture parts. The facility is currently operating nine hour shifts Monday through Friday with 23 employees. Ms.Martha Reese,President and David Adams,Maintenance Manager,accompanied me during this inspection. The plant processes approximately 5,000 to 6,000 bd. ft. of lumber per week on the average. 2. Facility Contact Information: During the inspection,I verified the facility contact information in IBEAM. Only the email address for Ms. Reese was changed in IBEAM. Piedmont Wood Products,Inc. April 14, 2022 Page -3- 3. Compliance history file review: The facility was issued a Notice of Violation for one violation of 2D .0512 Particulates from Wood Products Finishing Plants on March 18,2016 and was resolved by a response from the violator on April 8,2016. The facility was issued a Notice of Violation for one violation of Subpart 6J(boiler inspection). This was resolved by a boiler inspection conducted on January 11,2017. The current compliance status is discussed in the remaining portion of this inspection report. 4. Observations of permitted air emission sources and control devices: Emission Emission Source Control Control System Source ID Description System ID IDescription WC-1 Woodworking operations BF-1 Bagfilter(3,060 square feet of filter area). Observed: The bagfilter is installed on two woodwaste collection systems in the plant. Collected woodwaste from the bagfilter is transferred to a woodwaste storage bin(ID No. I-WSB-1)via a closed- loop transfer cyclone(ID No. I-CD-2; 84-inch diameter). The cyclone does not vent back into the bagfilter or the atmosphere. The bagfilter exhaust can be vented to the outdoor atmosphere or returned into the plant. During this inspection,the woodworking operation and bagfilter were in operation. 5. Observations of insignificant air emission sources and control devices listed on the current permit: Source of Source of Title V Source Exemption Regulation TAPS? Pollutants? I-B 1 -No. 2 fuel oil-fired boiler(0.47 million Btu per hour maximum heat 2Q .0102 (c)(2)(13)(i)(11) Yes Yes input) subject to GACT Subpart JJJJJJ Observed: The boiler is used for comfort heat as required. It is manufactured by Federal Boiler (National Board#580171,mfg date 1973). The boiler is subject to the Boiler GACT—Subpart 6J. Compliance with the GACT is discussed in Item 8. of this report. The boiler is not currently operating. 6. Observations of air emission sources and control devices not listed on the current permit: Wood blocks that are considered waste are manually dumped into a woodwaste grinder. The grinder does not vent to the atmosphere. The grinder vents to the storage bin through the existing closed-loop transfer cyclone(ID No. I-CD-2). The grinder was not in operation during this inspection. Piedmont Wood Products, Inc. April 14, 2022 Page -4— 7. Compliance with specific permit conditions and limitations: a. Condition A.2.—"Emissions Inventory Requirement". At least 90 days prior to the expiration date of the permit,the Permittee shall submit the air pollution emission inventory report. The report shall be submitted to the Regional Supervisor,DAQ. The report shall document air pollutants emitted for the 2021 calendar year. Observed: I reminded Ms. Reese that the permit renewal will require an emissions inventory and that she will use data from the 2021 calendar year. I reminder her that this information would be due July 31,2022. b. Condition A.3. 15A NCAC 2D .0512 "Particulates From Wood Products Finishing Plants," the Permittee shall not discharge particulate matter caused by the working, sanding,or finishing of wood without providing, as a minimum for its collection, adequate duct work and properly designed collectors,or other such devices as approved by the Commission. As part of this requirement,the following procedures must be followed during the woodwaste storage bin dumping operations: 1. The canvas curtains,front and back,must be completely lowered to the ground and the bin dumping area totally enclosed during the short bed truck loading operation. 2. Loading of a long bed truck will be done in sections(front,middle,and back of the long bed truck) and the curtain position will be as follows: i. During the front section loading operation,the front canvas curtain must be completely lowered to the ground and the back curtain should be extended across the top of the trailer or in the bed of the trailer in the most effective position which must extend to each side of the trailer walls. ii. During the middle section loading operation,the front and back canvas curtain should be extended across the top of the trailer or in the bed of the trailer in the most effective position which must extend to each side of the trailer walls. iii. During the back section loading operation,the back canvas curtain must be completely lowered to the ground and the front curtain should be extended across the top of the trailer or in the bed of the trailer in the most effective position which must extend to each side of the trailer walls. 3. Dust emissions from the short bed truck and long bed trailer dumping operation must last no longer than six(6)minutes and only once per six(6)hour period. 4. Ripped or torn curtains must be repaired or replaced as soon as possible but no later than before the next period of bin dumping occurs. 5. Collected woodwaste should be disposed of properly. Dumping or storing woodwaste on the ground is prohibited on plant property. Piedmont Wood Products,Inc. April 14, 2022 Page - 5— 6. Employees trained in the proper woodwaste storage dumping procedures by the Permittee must oversee the woodwaste storage dumping process each time it occurs. Observed: The canvas curtains were in place and appeared to be in good condition.No sawdust waste was observed at exhaust points around the bagfilter,and the ductwork appeared to be properly maintained. Woodwaste was in the process of being dumped into the truck trailer during this inspection. Compliance with this permit condition is indicated. 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 permit condition is indicated. d. Condition A.5.—"Notification Requirement". Notify DAQ of excess emission that last more than four hours that result from a malfunction, a breakdown of process or control equipment or any other abnormal conditions. Observed: Ms. Reese stated that there had been no excess emissions to report. The MRO has not received any complaints since the last inspection. Compliance with this permit condition is indicated. e. Condition A.6. - 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources"requires the facility to develop and submit a fugitive dust control plan if the facility cause or contribute to substantive dust complaints. Observed: A complaint was received on December 1,2016 concerning the dust from this facility.No violation was documented at that time. No fugitive dust was observed during this inspection. Compliance with this permit condition is indicated. f. Condition A.7.—Bagfilter I&M Requirements. Conduct an annual internal inspection of the bagfilters. In addition,perform periodic inspections and maintenance as recommended by the equipment manufacturer and list corrections made and dates of actions in a logbook. Observed: The records on the inspection and maintenance of the bagfilter are being kept up to date and maintained for easy access by the inspector. The last internal inspections took place on October 9,2020, October 15,2020,March 18,2021 and June 27,2021. I reminded Mr. Adams and Ms. Reese that an internal inspection would be due before June 27 of this year. The logbooks were being properly maintained. Compliance with this permit condition is indicated. (See example below) Piedmont Wood Products,Inc. April 14, 2022 Page -6— _M&a 519A1t !n .2✓l�) Yscy_� _ J aF - fiov " R�,S A5 r,.� TA6Gah �T�M1..... � GF Rolf-Y�uRP AxA. S�Ic o- i .yY.rv.w wyg ,� c'r iS a220 ;ao - 6t�5iC LY:W CxT 1'4 .�080 v1Yt __R�f'_1_Ifl''Jp11 _ aafnr ryaf ��N.l "DVL7 Wu� AdhNte --`De2 R MVG _ —�BiL 'D6A 8. NESHAP/NSPS Review The facility does not have a generator, fire pump or gasoline storage tank onsite. The facility is subject to NESHAP Subpart 6J. This Rule applies to the No 2 fuel oil-fired boiler (ID No. I-B1; 0.47 million Btu per hour maximum heat input). The boiler is considered an existing unit since it was constructed prior to June 4,2010. The facility must implement a tune- up program as a management practice. The boiler is less than 5 million Btu per hour and a seasonal-use boiler. A boiler tune-up is required every five years. The boiler was not required to perform an energy assessment, since it is rated at less than 10 million Btu per hour. The facility must comply with the notification,recordkeeping and reporting requirements under General Provisions—Subpart A. They must also maintain documentation on file that demonstrates compliance with the tune-ups. Facility records indicate that a boiler tune-up was performed on January 11,2017 by Link Boiler. The next tune-up will be due January 11,2022. The tune-up due on January 11,2022 had not been completed at the time of this inspection. 9. Summary of changes needed to the current permit: None. 10. Compliance assistance offered during the h�pection: None. 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. Piedmont Wood Products,Inc. April 14, 2022 Page -7— 12. Compliance determination: Based on my observations,this facility did not appear to be in compliance with the applicable air quality regulations at the time of this inspection. An NOV/NRE will be issued for not completing the boiler tune-up on time. RCM: c: MRO File Https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00030/INSPECT_20220414.doc x