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HomeMy WebLinkAboutAQ_F_1900039_20210219_CMPL_InspRpt (4) NORTH CAROLINA DIVISION OF Raleigh Regional Office WTW AIR QUALITY Southern Veneer Specialty Products,LLC - Moncure Inspection Report NC Facility ID 1900039 Date: 03/02/2021 County/FIPS: Chatham/037 Facility Data Permit Data Southern Veneer Specialty Products,LLC-Moncure Permit 03424/T29 306 Corinth Road Issued 4/20/2020 Moncure,NC 27559 Expires 3/31/2025 Lat: 35d 36.5760m Long:79d 2.9560m Class/Status Title V SIC: 2436/Softwood Veneer And Plywood Permit Status Active NAILS: 321212/Softwood Veneer and Plywood Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP/Title V Thomas Reams Thomas Reams Thomas Reams MACT Part 63: Subpart ZZZZ EHS Coordinator EHS Coordinator EHS Coordinator NSPS: Subpart Dc, Subpart IIII (910)605-9258 (910)605-9258 (910)605-9258 Compliance Data Comments: IN VIOLATION. Emergency fire pump engine IES-23 is not installed with a non-resettable hour meter in violation of NSPS IIII and thus Inspection Date 02/19/2021 GACT ZZZZ. Inspector's Name Matthew Mahler �b� � Operating Status Operating Inspector's Signature: /'/ Compliance Status Compliance-inspection Action Code FCE Inspection Result Violation Date of Signature:August 16,2021 Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2019 54.88 0.7900 48.98 60.86 19.21 54.63 9429.92 2018 60.22 0.8400 52.25 82.52 34.83 60.00 13256.42 2017 54.85 0.6900 43.01 70.06 31.03 54.64 12011.69 *Highest HAP Emitted(in pounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 07/15/2019 NOV Permit Permit Condition 08/12/2019 07/15/2019 NOV Part 60-NSPS Subpart Dc Small Industrial- 08/12/2019 Commercial-Institutional Steam Generating Units 07/15/2019 NOV 2D .0614 Compliance Assurance Monitoring 08/12/2019 07/15/2019 NOV 2D .I I I I Maximum Achievable Control Technology 08/12/2019 11/20/2018 NOV Permit Late Report(excluding ACC) 12/19/2018 11/20/2018 NOV Part 60-NSPS Subpart IIII Stationary Compression 12/19/2018 Ignition Internal Combustion Engines Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested (I)DIRECTIONS TO SITE: Southern Veneer Specialty Products, LLC -Moncure (Southern Veneer)is located at 306 Corinth Road(SR-1916)in Moncure,NC, Chatham County. From Raleigh,take US-1 South to Old US-1 (SR- 1011) and turn south(right). Travel approximately 3.5 miles and turn east(left)on Corinth Road(SR-1916). The plant entrance is on the right,just past the railroad tracks. (II)FACILITY DESCRIPTION: The Moncure facility was recently purchased by Southern Veneer. This plywood plant manufactures plywood from pine veneer. Due to market conditions, the facility is not manufacturing plywood from hardwood(poplar)veneer. The plywood ranges from 3 to 9 plies, and from 11/32 -inch to 1 '/a-inch thick. The facility receives trees, cuts them to length(10 feet), and debarks the wood. The bark is hammer milled, transferred to silos, and used as wood fuel. The logs are heated in steam vats for about 24 hours to soften. The more the logs are heated, the less glue is required. The logs are then sent to a spindle lathe. The lathe cuts continuous,thin sheets of veneer from each log. The 22-inch core of the log is sold as battens (for packaging). Wood chips are further processed for wood fuel or for sale to other wood products facilities. Veneers are cut into 4 feet x 8 feet pieces and then dried in dryers, glue is applied, pieces are aligned in the composer and lay-up lines, and then are pressed in the plywood presses. The plywood is then sawed to specifications and stacked for sale. Wood waste is used as fuel. Most of the plywood is used to construct upholstered furniture. The facility produces softwood plywood,hardwood plywood, and composite plywood(both softwood and hardwood). The actual production of the plywood typically occurs six days/week. The dryers typically operate five days per week, 24 hours per day. Presently,there are 120 employees at the facility. Be prepared to use standard safety items at this facility. (III)INSPECTION SUMMARY: On February 19, 2021, I(Matt Mahler)arrived on the site to perform a compliance inspection. The Facility Contact,Mr. Tom Reams,met me at the main office of the facility. We proceeded to Mr. Reams' office where we reviewed the permit conditions and required records. Records are maintained at the utility building. The records appeared to be well maintained and complete. After the records review, we proceeded to tour the facility. Most of the equipment was operating at the facility. IES-23, emergency fire pump engine was observed with 2.1 hours on the hours meter. Mr. Reams indicated that IES-23 had been sent to New Jersey for repair in January 2021 and the source was returned with the hours meter reset. Through further discussions, Mr. Reams indicated that IES-23, diesel fire pump engine does not have a non- resettable hour meter and he clarified that a computer programmer employed by Southern Veneer had reset the hour meter prior to shipping. Subsequently, Southern Veneer Specialty Products was found to be in violation of 40 CFR 60, Subpart IIII and 40 CFR 63, Subpart=for not monitoring engine hours for IES-23 emergency fire pump engine with a non-resettable hour meter. Comments about observations made during the inspection are provided below for each of the emission sources and specific air quality regulations listed in the facility's current air permit. Overall, the facility appeared to be managed well. (IV)PERMITTED EMISSION SOURCES: On the day of the inspection,the facility was operating under Air Permit No. 3424T29. This permit became effective on April 20, 2020 and expires on March 31, 2025. This permit includes the following emission sources and control devices: (a) one multicyclone (ID No. CD-02) installed on a blend chamber controlled fluidized bed wood burner(ID No. ES-01-A) and boiler ES-01-B); There was some exhaust coming from the wood burner dump stack on the day of the inspection. According to the staff, the boiler dump stack exhausts excess gases (and heat)when not required by the veneer dryers. The flow diagrams indicate that the heated gases from the burner are directed either towards the boiler(to produce facility steam)or to the dryers to process the veneer. In another diagram provided by the facility, it appears that the gases headed to the dump stack and the gases directed towards the dryers are processed by a multicyclone. Some of the gases from the boiler and the dryers are recirculated back to the wood burner. The balance of the gases are emitted from the six stacks (3 for each dryer)or escape as fugitive emissions. The boiler has a maximum rating of 150 psi and a maximum rated heat capacity of 29.79 mmBtu/hr. The wood burner was operating on the day of the inspection. (b) two direct wood-fared veneer dryers (ID Nos. ES-09 and ES-10); ES09 is referred to as 62 little and is 12 feet wide. ES 10 is referred to as 72 and is 16 ft wide. Both the dryers were operating on the day of the inspection. These two dryers directly utilize the exhaust gases from the fluidized bed wood burner. The visible emissions of the plume from this dryer was 0%opacity. (c) one cyclone (CD-03-WWTC) and one bagfilter(ID No. CD06) installed on: • two string machines including saws (ID Nos. ES03-SMS-1,2); • one core saw(green or dry veneer) (ID No. ES03-CS); • one strip saw (ID No. ES03-SS); • one core composer saw (ID No. ES03-CC); • one panel sawing system (ID No. ES03-PSS); • one plywood hog(ID No. ES16); and • green wood sizing operations (ID No. ES17); • tongue and groove saw (plywood fanishing)(ID No. ES22) The core saw and the panel sawing system had operated early during the day,but was not operating during the onsite tour. The core composer with saw was operating. All other sources were not operating during the onsite tour. Mr. Reams indicated that the two string machines have not operated since 2018. The bagfilter(CD06)was operating at the time of the physical tour and no visible emissions were evident. The magnehelic gauge reading was 0.5 inches of water; Mr. Reams indicated that a good operating range is from 0-3 inches of water. Of note, the strip saw is referred to as the wedge saw and the plywood waste hog is referred to as the dry hog. (d) one cyclone (ID No. CD18) installed on rechip blow hog(ES14) along with one woodwaste transfer cyclone (CD-03-WWTC)/one bagfilter(ID No. CD06); This equipment was operating at the time of the inspection with no visible emissions evident. (e) one bagfilter(ID No. CD05) installed on a wood sander(ID No. ES04)along with one woodwaste transfer cyclone (CD-03-WWTC)/6ne bagfilter(ID No. CD06); This equipment was not operating at the time of the inspection since the facility is not currently making plywood from hardwood(poplar)veneer. In the most recent inspection, the source was operating with no visible emissions evident. 69 one cartridge falter(ID No. CD21) installed on a dry wood residual storage silo (ID No. ES12); The silo has been repaired from an earlier fire. Presently the silo appears to be in adequate condition. 0,) one vat operation (ID No. ES20); There were vats in operation during the physical tour. Two are collocated in one structure. The other five vats are adjacent to each other forming another structure. (h) one end sealer spray booth (ID No. ES21); The equipment was not-in-service. Mr. Reams believes that ES21 was taken out of service in the 2015-2016 timeframe. (i) one glue mixing operation (ID No.ES-13-GM0); The equipment appeared to be sound and well maintained. The equipment was operating during the tour. 6) one curtain coater(ID No.ES-13-CC); The equipment along with ES-13-40HP, 40 panel hot press, is referred to as `layup' and appeared to be sound and well maintained. The equipment was not operating during the tour as the personnel were on break. (k) one paper overlay operations (ID No.ES-13-PO); The equipment appeared to be sound and well maintained. The equipment was not operating during the tour as the personnel were on break. (l) one plywood spreader(ID No.ES-13-PS); The equipment has been removed from the facility. Mr. Reams said that the equipment was possibly removed from site in the 2015-2016 timeframe. (m) one 25 panel hot press (ID No.ES-13-25HP); and This equipment was not-in-service. (n) one 40 panel hot press (ID No.ES-13-40HP); The equipment along with ES-13-CC, Curtain coater,is referred to as `layup' and appeared to be sound and well maintained. The equipment was operating during the tour. (V)APPLICABLE AIR QUALITY REGULATIONS: As is the case with all Title V permits,Air Permit No. 03424T29 lists all of the air quality regulations that apply to each of the permitted emission sources. To avoid redundancy in this report,the applicable air quality regulations are discussed individually, and all of the permitted emission sources that are subject to a specific regulation are noted. (1) 1 SA NCAC 2D.0512:PARTICULATES FROM MISCELLANEOUS WOOD PRODUCTS FINISHING PLANTS —The following emission sources are subject to 2D.0512:All woodworking operations and Edge Sealing Spray Booth (ID Nos. ES-03-SMS-1,2, ES-03-CS, ES-03-SS, ES-03-CC, ES-03-PSS, ES-04, ES-12, ES-14, ES-16, ES-17, ES-21, &ES22). IN COMPLIANCE-In accordance with 15A NCAC 2D .0512,the permittee shall not cause,allow, or permit particulate matter caused by the working, sanding, or finishing of wood to be discharged from any stack,vent,or building into the atmosphere without providing, as a minimum for its collection, adequate duct work and properly designed collectors. All duct work and control devices installed on woodworking equipment were observed during the inspection in good physical condition. No particulate emission testing is required for any of these sources by the facility's air permit. The permit does require the facility to conduct monthly and annual inspections of the cyclones and bagfilters installed on the wood working equipment, record the results of any inspection and maintenance activities in a logbook, and submit a semiannual deviation report to DAQ. Also,the permit requires that weekly visible emission monitoring be performed on the other wood-finishing units. Upon request,the facility provided records of the weekly,monthly and annual inspection activities. Additionally,the facility has submitted the required semiannual reports on time summarizing the facility's monitoring and record keeping activities. (2) 15A NCAC 2D.0515:PARTICULATES FROM MISCELLANEO US INDUSTRIAL PROCESSES- The following emission sources are subject to 2D.0515: The fluidized bed wood burner(ID No. ES-01-A), the associated boiler(ID No. ES-01-B), and two associated direct wood-fired veneer dryers (ID Nos. ES-09, ES- 10). IN COMPLIANCE-The particulate emission limit for the wood burner and associated veneer dryers is determined by the processed material in the system including the wood fuel and the dried veneer. To demonstrate compliance with this requirement,the previous air permit(T24—the first revision in the renewal cycle)required that a performance test(for particulate matter) and the test results be submitted within 180 days of the permit issuance. This would make for a July 20, 2015 due date. Actually,the required performance test was not completed until June 30, 2016 and the report was not submitted until July 29, 2016. A Notice of Violation was issued on August 10, 2015 due to the lateness of the required testing project. When the test results were finally submitted and reviewed,the Stationary Source Compliance Branch(SSCB)indicated that the test results (12.1 lb./hr.)met the particulate limit(17 lb./hr.). One of the reasons for the delay of the testing project was the fact that the facility was advised to change to a different type of air jet in the wood burner. These new jets apparently caused combustion issues. The facility eventually removed these air jets and replaced them with the original type. The most recent annual internal inspection of CD02 was conducted on December 28, 2020. (3) 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMB USTION SOURCES- The following emission sources are subject to 2D.0516: The fluidized bed wood burner(ID No. ES-01-A). IN COMPLIANCE-The sulfur dioxide emission limit for each of these sources is 2.3 pounds per million Btu heat input. Since the facility burns exclusively wood waste and diesel fuel in its combustion equipment,the 15A NCAC 2D .0516 sulfur dioxide emissions standard should be achieved during normal operating conditions. Sulfur dioxide emissions testing/monitoring/record keeping/reporting is not required for these sources by the facility's air permit. (4) 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-All of the permitted emission sources are subject to 2D.0521. IN COMPLIANCE-The visible emission limit for all plant emission sources is 20%opacity. During the inspection,visible emissions related to the dryer operation were observed as 0% - 10%opacity, which is 10%more than the opacity noted during a prior inspection report. The following excerpt was taken from the 2017 inspection report. "On a previous site visit(October 23, 2013)while travelling to Arauco (across the road) to perform a stack test observation. I(Steve Carr) observed and photographed stacklrooftop visible emissions that appeared to be excessive. On the following week, I sent an email with attached photographs to Mr. Van Gelder. Mr. Van Gelder indicated that the new owner(Southern Veneer)was motivated to correct the visible emissions problem. On January 6, 2014, Mr. Van Gelder sent an email that described some equipment modifications that the facility is considering that might help decrease visible emissions. Some of the modifications listed in the email include the replacement ofM62 baffles, electronic control upgrades for the boiler, and installing variable frequency drives. These changes included new ductwork to capture fugitive emissions and were noted on the last inspection (January 14, 2015). The ductwork modifications were discussed during the last inspection (January 29, 2016) and it appears that they were not effective in decreasing fugitive emissions. During this inspection (March 9, 2017), the visible emissions from the dryer stacks did not appear to be remarkable." I discussed the above modifications with Mr. Reams. He indicated that all of these modifications were implemented in 2018, one year before Boise Cascade sold the facility to Southern Veneer. I indicated to Mr. Reams that I had observed from the roadway, excessive visible emissions between the manufacturing area and the office building on December 16, 2020,while in transit to another facility. Mr. Reams replied that visible emissions at the facility have never been greater than 20%opacity. The permit does require the facility to perform periodic visible emissions observations on the boiler and woodworking operations, record the results of the observations in a logbook, and submit a summary report of the observations on a semiannual basis. Upon request, the facility provided records of the required visible emission observations. Additionally,the facility has submitted the required semiannual reports on time summarizing the facility's monitoring and record keeping activities. (5) 15A NCAC 2D.0524:NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60, Subpart Dc) - The following emission source is subject to NSPS Subpart Dc:Boiler(ID No. ES-01-B). IN COMPLIANCE-To comply with the requirements of 40 CFR 60, Subpart Dc -Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units,the facility must record and maintain records of the amount of wood fuel burned during each month. Mr. Reams provided records of monthly wood fuel combusted in ESO1-B. (6) 15A NCAC 2D.0614: COMPLIANCE ASSURANCE MONITORING- The following emission sources are subject to 2D.0614: The fluidized bed wood burner(ID No. ES-01-A). and woodworking operations (ID Nos. ES- 03-SMS-1,2, ES-03-CS, ES-03-SS, ES-03-CC, ES-03-PSS, ES-04, ES-12, ES-14, ES-16, ES-17, &ES-22). IN COMPLIANCE-To comply with 15A NCAC 2D .0614,the permittee is required to record the differential pressure across the multicyclone (CD02)to ensure that the pressure drops fall between 4" and 13". This pressure requirement was recently added in the T25 version of the facility air permit. The facility is monitoring the pressure drops across the multicyclone as required and most differential pressure records were available for review. The facility is required to provide a summary of excursions in their semi-annual reports. The 2nd half 2020 semiannual report was received on January 29, 2021 and reviewed as complete. For the woodworking operation, a Method 22 type observation is required to be performed daily on each bagfilter outlet. The records I reviewed during the inspection appeared to indicate compliance to this daily opacity observation requirement. (7) 15A NCAC 2D.1100 and 2Q.0711: TOXIC AIR POLL UTANT REQUIREMENTS-All of the permitted emission sources are subject to 2D.1100 and 2Q.0711. IN COMPLIANCE-Through the results of past air modeling,the emission rates of air pollutants were established. From a review of the 2019 Emission Inventory, it appears that the emission rates for the pollutants of concern were below the listed thresholds in the air permit. (8) 15A NCAC 2Q.0317:LIMITATION TO AVOID BEING A MAJOR FOR HAZARDOUS AIR POLL UTANTS-All of the permitted emission sources are subject to 2Q.0317. IN COMPLIANCE-To avoid being a major source for hazardous air pollutants (HAPs)under 40 CFR Part 63,the facility must limit facility-wide emissions to 10 tons per year of any listed HAP and 25 tons per year for all HAPs combined. The former owner of this facility(Boise Cascade)performed an internal audit in April, 2014. During the audit, it was discovered that the hardwood emission factor that was being used for methanol emissions from the presses was potentially lower than it should be. The methanol emission factor that was being used had been taken from EPA AP-42 and was based on hardwood plywood being processed with a urea formaldehyde-based adhesive. In contrast,this facility processes its hardwood plywood with a phenol formaldehyde-based adhesive which potentially might emit higher methanol emissions. The stack test performed on December 10,2014 indicated that the methanol emission factor for their hardwood plywood should be 0.116 lb./MM sq. ft. instead of the AP-42 factor (0.032 lb./MM sq. ft.). This same stack test indicated that the methanol emission factor for their softwood plywood should be 0.106 lb./MM sq. ft. instead of the AP-42 factor(0.14 lb./MM sq. ft.). The impact of changing these emission factors increased the facility-wide 12-month rolling methanol emissions. One of the highest 12-month rolling totals of methanol for CY 2020 was 5.3 tons in December 2020. One of the lowest 12-month rolling totals of methanol for CY 2020 was 4.6 tons in both April and June 2020. The facility must also maintain monthly HAPs emissions records and Mr. Reams provided these records for review. (9) 15A NCAC 2D.1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS-All of the permitted emission sources are subject to 2D.1806. IN COMPLIANCE—To comply with 15A NCAC 2D .1806,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. No objectionable odors were detected during the compliance inspection. No odorous emissions testing/monitoring/record keeping/reporting is required by the facility's air permit. There are no odor complaints recorded in the Complaint Module (IBEAM). (VI) OTHER REGULATORY REQUIREMENTS: (1) 15A NCAC 2D.0524:NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60, Subpart IIII) - The following emission sources are subject to NSPS Subpart IIII: The 250 horsepower(maximum) diesel fire pump (IES-23). IN VIOLATION—To meet the requirements of this regulation,the generator engine must meet a particulate matter, carbon monoxide, and a combined NMHC +NOx limit. Also, the facility has to maintain the engine according to the manufacturer's recommendation. The facility was able to provide a Certificate of Conformity for this engine (IES-23). This is the primary backup pump, which automatically turns on when the water pressure drops below a set point through the facility(100 psi). According to their staff, there are incidences where the pumps are needed for fire-related issues. The hour meter on the generator indicated 1112.3 hours on the day of the inspection and 979.9 hours during the September 2018 inspection. The facility had received an NOD dated May 31, 2018 at a time when the fire pump engine was classified for emergency use. This NOD was for exceeding the 50-hour limit for non-emergency use for IES-23 according to the Subpart 1111 requirements of the prior permit version T27. Since then, the facility has installed an electric jockey pump engine to supply process water as a backup pump. The facility modified their permit(current T28)to reclassify IES-23 as a non-emergency engine. With permit T29, IES- 23 was reclassified as an emergency fire pump engine. During this inspection,the facility provided records of maintenance which showed that the most recent engine maintenance was conducted on January 14, 2021. The facility conducted regularly scheduled maintenance on a 6-month,yearly and two-year maintenance schedule. IES- 23 was observed with 2.1 hours on the hours meter. Mr. Reams indicated that IES-23 had been sent to New Jersey for repair in January 2021 and the source was returned with the hours meter reset. Prior to the maintenance, Mr. Reams indicated that the unit had an hour meter reading of 1148 hours. On March 9, 2021, I called Mr. Reams to find out if IES-23 has a second mechanical-type non-resettable hour meter. Mr. Reams indicated that IES-23, diesel fire pump engine does not have any non-resettable hour meter. He said he can install a non-resettable mechanical type hour meter if needed. I reminded him that this is a monitoring requirement of GACT 4Z and NSPS IIII. Additionally, Mr. Reams clarified that a computer programmer employed by Southern Veneer had reset the hour meter prior to shipping to the 3rd party contractor that rebuilds Clarke pumps. This was done because of the engine warranty, even though Mr. Reams stated that resetting the meter wasn't a required condition of the warranty. Subsequently, Southern Veneer Specialty Products was found to be in violation of 40 CFR 60, Subpart IIII for not monitoring engine hours for IES-23 emergency fire pump engine with a non-resettable hour meter. (2) 15A NCAC 2D.I I11:MAXIMUM A CHIE VABLE CONTROL TECHNOLOGY(40 CFR 63, Subpart ZZZZ)- The following emission sources are subject to 2D.I I11: The 190-horsepower diesel fire pump (IES-23) and the 250 horsepower diesel fire pump (IES-19). IN VIOLATION—Since IES-23 was manufactured after 2006, satisfying the requirements of 40 CFR 60, Subpart IIII, satisfies the requirement of this regulation. See the NSPS IIII discussion above for details on this GACT ZZZZ violation. Subsequently, Southern Veneer Specialty Products was found to be in violation of 40 CFR 63, Subpart ZZZZ for not monitoring engine hours for IES-23 emergency fire pump engine with a non- resettable hour meter. Past records indicate that IES-19 is complying with the maintenance requirements of this regulations. The most recent engine maintenance was conducted on January 7, 2021. According to the hourly records (as noted above)the non-emergency usage of IES-19 appears to be less than the 50-hour limit. This unit had 1520 hours on January 5, 2014, 1588 hours during the 2017 inspection, 1631.4 hours on September 6, 2018 and 1658.2 hours on June 24, 2019. IES-19 is currently out for repair and will be installed in March 2021. (VII)EXEMPT EMISSION SOURCES: The facility currently has several emission sources listed on the Insignificant Activities List attached to the current air permit. Some of these sources were observed during the inspection. No concerns were noted with regard to their operation or permit exemption status. The two plywood spreaders (IES-I3-PS 1/2)have never operated. IES-GEN1 is used for the server. IES-19 is currently out for repair and will be installed in March 2021. [ES-23 was observed with 2.1 hours on the hours meter. Mr. Reams indicated that IES-23 had been sent to New Jersey for repair in January 2021 and the source was returned with the hours meter reset. Prior to the maintenance, Mr. Reams indicated that the unit had an hour meter reading of 1148 hours. On March 9, 2021, I called Mr. Reams to find out if IES-23 has a second mechanical-type non-resettable hour meter. Mr. Reams indicated that IES-23, diesel fire pump engine does not have any non-resettable hour meter. He said he can install a non-resettable mechanical type hour meter if needed. I reminded him that this is a monitoring requirement of NESHAP GACT 4Z and NSPS IIII1, Additionally, Mr. Reams clarified that a computer programmer employed by Southern Veneer had reset the hour meter prior to shipping to the 3rd party contractor that rebuilds Clarke pumps. This was done because of the engine warranty, even though Mr. Reams stated that resetting the meter wasn't a required condition of the warranty. Subsequently, Southern Veneer Specialty Products was found to be in violation of 40 CFR 60, Subpart IIII and 40 CFR 63, Subpart ZZZZ for not monitoring engine hours for IES- 23 emergency fire pump engine with a non-resettable hour meter. (VIII)ENFORCEMENT HISTORY: Southern Veneer has been issued one Notice of Violation(NOV)according to DAQ records. The facility received an NOV dated July 15, 2019 for not maintaining 3.B,NSPS Subpart Dc recordkeeping, CAM monitoring and recordkeeping, and major source HAP Avoidance monitoring. The former Moncure Plywood has been issued two Notices of Violation/Notice of Recommendation for Enforcement (NOV/NRE), five Notices of Violation(NOVs), and two Notices of Deficiency(NOD)according to DAQ records. In 2018,the facility had submitted a modified permit application to NCDAQ to reclassify IES-23 as a non- emergency engine under NSPS 1111. Prior to submitting this application,the facility exceeded the 50-hour limit and the 100-hour limit(sum of non-emergency, readiness testing and maintenance use)in 2018. A NOV was issued to the facility on November 20, 2018 for the 2018 exceedances. On May 31, 2018,the facility was issued an NOD per the requirements of NSPS IIII for exceeding the 50-hour limit for non-emergency use for IES-23. On August 10, 2015, a NOV was issued to the facility for not performing a stack test within the required time frame. On June 5, 2014, a NOD was issued to the facility for not maintaining records for the required five years. On February 8, 2011, an NOV was issued due to a late stack test report. On February 26, 2010,a NOV/NRE was issued for missed visible emissions observations and inspections. The company was assessed$4666 in civil penalties for these violations. On November 1, 2007, the company was issued a NOV for not maintaining a cyclone unit effectively so to prevent excess particulate emissions. Also,this same NOV noted that records tracking the BTU heat input to the steam generating unit were not complete. On June 7, 2007,the company was issued an NOV/NRE for various Title V monitoring and record keeping violations. The company was assessed$2913 in civil penalties for these violations. Prior to that,the company was issued an NOV on June 14, 2006 for previous Title V monitoring and record keeping violations. No civil penalties were assessed against the company in this case. (IX) STACK TEST REVIEW: As indicated above in Section V. (2), Air Permit 03424/T24 requires that a particulate test be performed on the fluidized bed wood burner(ESO1-A) and the associated dryers (ES09, ES 10)within 180 days from the permit issuance date. This permit being issued on January 21, 2015 would require that the test results be submitted by July 20, 2015. The required performance test was finally completed on June 30, 2016 with the test results submitted on July 29, 2016. The results were reviewed by SSCB with the conclusion that compliance to the particulate standard was indicated. A performance test to determine more accurate methanol emission factors for the presses was performed on December 10, 2014. Another performance test was performed on November 20, 2012. The purpose of the testing was to demonstrate compliance with 40 CFR 63 Subpart JJJJJJ(6J)by measuring the effectiveness of a tune up by monitoring carbon monoxide (CO)concentrations. The test results were accepted by SSCB. (X) CLEAN AIR ACT SECTION 112(r)REQUIREMENTS: Pursuant to 15A NCAC 2D .2100 "Risk Management Program," if the Permittee is required to develop and register a risk management plan pursuant to Section 112(r)of the Federal Clean Air Act, then the Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part 68. IN COMPLIANCE—Southern Veneer Specialty Products is subject to the 112(r)program general duty clause, but does not maintain regulated chemicals onsite above the threshold quantities,which would require a risk management plan. (XI)EMISSION INVENTORY REVIEW: The following review was provided by the 2019 Emission Inventory DAQ internal comments in IBEAM. Changes in emissions that are greater than 10%between 2018 and 2019 inventories are explained as follows. CO,VOC, acetaldehyde, cumene, ethyl chloride, ethylene dichloride, formaldehyde, methyl bromide,methylene chloride,vinyl chloride,vinylidene chloride, and xylene emission decreases are due to a 25%decrease in throughput for OS26,veneer dryers and wood burner(softwood)and a 70% decrease in throughput for OS30,veneer dryers and wood burner(hardwood). Acrolein and benzene emission decreases were due to a decrease in throughput for OS26. Methanol emission decrease was due to a 45%decrease in throughput for OS 10, glue mixing and hot presses (hardwood) and a 16%decrease in throughput for OS28,glue mixing and hot presses (softwood). Emission decrease of phenol is due to decrease in throughput for OS 10. Emission decrease of propionaldehyde is due to a decrease in throughput of OS30. Several pollutants had emission changes greater than 10%but the lbs/yr was less than the de minimus. (XII) CONCLUSIONS/RECOMMENDATIONS: Based on observations made during the December 19, 2020 inspection and supplemental information received on March 9, 2021, Southern Veneer Specialty Products was found to be in violation of 40 CFR 60, Subpart[III and 40 CFR 63, Subpart ZZZZ for not monitoring engine hours for IES-23 emergency fire pump engine with a non-resettable hour meter. Southern Veneer Specialty Products appeared to be in compliance with all other requirements of their Title V permit. It is recommended that a Notice of Violation be issued to the facility for the violation of both NSPS IIIII and GACT ZZZZ. It is recommended that the facility be re-inspected in one year.