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HomeMy WebLinkAboutAQ_F_1800330_20201201_CMPL_CAV-Rpt NORTH CAROLINA DIVISION OF Mooresville Regional Office AIR QUALITY HM Frame Company,Inc. dba HM Woodworking, Inc. Inspection Report NC Facility ID 1800330 Date: 12/01/2020 County/FIPS: Catawba/035 Facility Data Permit Data HM Frame Company,Inc. dba HM Woodworking,Inc. Permit n/a 1903 GKN Way Issued n/a Newton,NC 28658 Expires n/a Lat: 35d 36.1494m Long: 8ld 12.6222m Class/Status Permit Exempt SIC: 2511 /Wood Household Furniture Permit Status Inactive NAICS: 337122/Nonupholstered Wood Household Furniture Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Daren Hefner Kevin Hefner Kevin Hefner Vice President of President President Manufacturing (828)428-2788 (828)428-2788 (828)428-2788 Compliance Data Comments: Inspection Date 12/01/2020 Inspector's Name Donna Cook Inspector's Signature: Manna C'vck JEF Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: 12101MV On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2012 11.36 --- --- --- --- 1.51 --- 2008 22.35 --- --- 0.1500 --- 3.00 53.00 *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 HM Frame Company, Inc. dba HM Woodworking,Inc. December 1,2020 Page 2 Type Action: _Full Compliance _Partial Compliance _Complaint X Other: Compliance Assurance Visit Evaluation Evaluation/Reinspection Investigation CAV Data Tracking: X Date submitted for initial review 12/01/2020 _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 12/01/2022 Directions: From Mooresville to Newton,travel Highway 150 west for 16 miles;past the Highway 16 intersection and immediately turn right onto East Maiden Road for 7.7 miles into Maiden;turn right on North Carolina Avenue(US-321 Business North); 1.8 miles turn right onto GKN Way(formerly Getrag Parkway); and 0.5 on the right is this facility. The street address is 1903 GKN Way. Safety Equipment: This company requires that safety glasses be worn by the inspector at this facility. Safety Issues: No safety issues noted by me during this visit. Lat/Long Coordinates: A review of the "Facilities Regulated by Air Quality" on the DAQ web site 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 of this facility are needed in IBEAM. The latitude and longitude coordinates of this facility are locked in IBEAM. Email Contacts: The email addresses for the facility, authorized,technical, and invoice contacts were verified by Ms. Donna Owens, secretary. No changes to the email addresses in IBEAM are needed. COVID-19 Information: Ms. Donna Owens, secretary at(828)428-2788, and I discussed the COVID-19 restrictions at this facility prior to this inspection. Ms. Owens stated that this company is allowing the inspector on-site access inside of this facility if a face covering(masks) is worn and the physical distancing of six feet(social distancing)is maintained from each other. The morning of the field portion of the compliance assurance visit(CAV)on December 1,2020,1 completed the NC Employee Screening for Employees Reporting Onsite form on the oshr.nc.gov web site Based on my responses to the questions in this form, I was able to proceed with the onsite CAV. The compliance assurance visit(CAV)was conducted by me outside of this facility. I met with Ms. Owens and Mr.Kevin Hefner,president,to conduct the inspection. Mr. Hefner escorted me outside of this facility to the two cyclones and the exhaust of the three-sided sanding booth. Both Mr. Hefner and I wore a face covering and maintained a distance of more than six feet(social distancing) from each other during the CAV. HM Frame Company, Inc. dba HM Woodworking,Inc. December 1,2020 Page 3 Compliance Assurance Visit: 1. General Information: The purpose of this site visit was to conduct a routine compliance assurance visit(CAV). This facility manufactures wooden furniture frames. This company operates this plant from 6:30 am to 2:30 pm, 5 days per week(Monday through Friday), 50 weeks per year for the woodworking and gluing operations. Mr.Kevin Hefner,president,accompanied me during the CAV. 2. Facility Contact Information: During the inspection, I verified the facility contact information in IBEAM with Mr. Hefner. No changes to the facility contacts are needed in IBEAM. 3. Compliance history file review: No problems have been noted in the last five years by DAQ prior to this visit. The current compliance status is discussed in the following sections. 4. Source Observations: This facility has one cyclone (144 inches in diameter) installed on woodworking equipment with associated storage silo and truck trailer, and one cyclone(88 inches in diameter)installed on a grinder. hi the main plant of this facility,woodworking equipment consisting of routers and saws vent woodwaste to the cyclone(144 inches in diameter) and then into truck trailers or a storage silo. The storage silo had been used as an emergency alternative if the truck trailers are full. Mr. Hefner stated that the storage silo is no longer being used by this facility. An augering system is used to transfer the woodwaste from the cyclone to two truck trailers located on either end of this system. The truck trailers are equipped with bin indicators that identify when the trailers are full of woodwaste. Mr. Hefner stated that two truck loads of woodwaste are collected every other day. Each truck trailer weighs approximately 15 tons. The woodwaste is sold by this company as boiler fuel and shipped to customers. The larger scraps of wood are conveyed to a vibrating shaker table and then to a grinder. Any woodwaste from the grinder is vented to the cyclone. This company uses the same augering system as described in the above referenced process to transfer the woodwaste from the cyclone (88 inches in diameter)to the truck trailers. The woodwaste from the woodworking operations and grinder appeared to be properly controlled by each cyclone. The exhausts of each cyclone is horizontal and uncapped. The two cyclones, grinder, various woodworking equipment and augering system were in operation during the visit. I observed no visible emissions from the two cyclones, grinder,various woodworking equipment, augering system, truck trailers, or associated ductwork during the visit. The visible emissions from these sources are limited to 20 percent opacity when averaged over a six-minute period. These sources were not exceeding the 20 percent opacity limit during the visit. This company uses two wood glues (assemby 433 and titebond 111)by the manufacturer, Franklin International, to assemble the furniture frames. The copies of the SDS are located in the file of this facility. The wood glue, assembly 433, is purchased in totes. Each tote contains 2,535 pounds of glue and the glue weighs 9.77 pounds per gallon. The glue has 0.029 pounds per HM Frame Company, Inc. dba HM Woodworking,Inc. December 1,2020 Page 4 gallon of VOC as indicated on the SDS. The wood glue, titebond 111, is purchased in buckets. Each bucket contains 5 gallons of glue. The glue has 0.4 pounds per gallon of VOC (ethylene glycol) in product as indicated on the SDS. Mr. Hefner stated that furniture frames was being glued at the time of this visit. I observed no visible emissions or detected any emissions from the gluing operations outside of this facility during this visit. This company reported during the last air emissions inventory for calendar year 2012 that the actual VOC emissions from a furniture leg dip process were 55.5 pounds. It was noted in an inspection report dated October 30, 2014 that furniture legs were dipped in a bucket and legs air dried on a rack. During this visit, Mr. Hefner stated that the furniture leg dip station is no longer being conducted at this facility. No furniture leg dip station was observed by me at this facility. This facility has a three-sided booth that had been used for conducting touch-up/quality control sanding. The booth has a fan that exhausts through a vertical and capped stack to the outdoor atmosphere. Mr. Hefner stated that the booth is no longer being used. I observed no visible emissions from the vertical and capped exhaust of the three-sided sanding booth located on the roof of this facility. This office has not received any fugitive dust emissions complaints regarding this facility. This company has paved roads at this facility. During the visit,I observed no fugitive dust from this facility. I asked Mr. Hefner if any excess emissions had occurred at this facility since the last inspection on October 31,2018. Mr. Hefner stated that no excess emissions had occurred at this facility. 5. NSPS/NESHAP Review: This facility is not subject to any NSPS or NESHAP regulations. There are no emergency or peak shaving generators,fire pump engines or gasoline storage tanks at this facility. 6. Exemption Qualification: This facility submitted a request to rescind Air Permit No. 07896R07, since the actual facility-wide emissions of particulate matter(PM10), sulfur dioxide,nitrogen oxides,volatile organic compounds, carbon monoxide,hazardous air pollutants(HAP) and toxic air pollutants(TAP), each are less than five tons per year and the total actual aggregate emissions of these pollutants are less than ten tons per year. During the exemption review by the permit engineer,this company provided information on the amount of woodwaste(wood chips) generated by woodworking operations and the grinder. The amount of wood chips sold as boiler fuel was 748.26 tons in 2012; 1,111.93 tons in 2013; 1,365.44 tons in 2014; 1,300.79 in 2015 and 766.756 tons from January 1 to August 30,2016. The wood glue was not evaluated by MRO DAQ permitting during the exemption review. The highest amount of wood chips produced in 2014 was used to calculate the facility-wide actual PM10 emissions. It was determined that 35%of the wood chips is from routing/rough sawing(95% shaving/chipping and 5%sawing) and 65%of the wood chips is from the grinder(100%milling& hog). The actual amount of woodwaste (wood chips)generated was 477.925 tons for routing/rough sawing and 887.575 tons for grinding. The DAQ woodworking emissions spreadsheet was used to calculate the actual facility-wide PM10 emissions as 0.27 tons per year. All PM10 emissions emitted were from routing/rough sawing. The grinder only produced PM emissions. HM Frame Company, Inc. dba HM Woodworking,Inc. December 1,2020 Page 5 This office sent a letter dated October 11,2016 exempting this facility from permit since the facility- wide actual particulate emissions(PM10),VOCs,HAPs, and TAPs are less than five tons per year and total aggregate emissions are less than ten tons per year. This company is keeping records of the actual tons of woodwaste (wood chips)generated and the pounds or gallons of wood glue used. Ms. Owens emailed me the usage of the woodwaste(wood chips) and glues in 2018,2019 and January 1 through October 31,2020. The woodwaste(wood chips) shipped for boiler fuel was 1,724.54 tons in 2018; 1,482.94 in 2019 and 1,434.88 from January 1 through October 31,2020. The wood glue usage for assemby 433 was 35,490 pounds in 2018; 53,235 pounds in 2019 and 22,815 pounds from January 1 through September 15,2020. The wood glue usage for titebond III was 40 gallons in 2018; 75 gallons in 2019 and 90 gallons from January 1 through September 15,2020. The usage records for the woodwaste(wood chips)and wood glues indicate that this facility still qualifies for exemption under 15A NCAC 2Q .0102(d). This facility has not changed or modified the equipment to increase emissions above the exemption thresholds since the rescission request. 6. Compliance determination: Based on my observations, this facility appeared to be in compliance with the air quality rules (21) .0521-visible emissions; 2D .0512-particulates from wood products finishing plants; 2D .0535-excess emissions and 2D .0540-fugitive dust emissions) at the time of the visit. The compliance assurance visit checklist is attached on page 6. DLC:Ihe c: MRO File https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/CATAWBA/00330/INSPECT 20201201_CAV.docx HM Frame Company, Inc. dba HM Woodworking,Inc. December 1,2020 Page 6 Compliance Assurance Visit Checklist rev.11/03/16 Facility Name: HM Frame Company,Inc.,dba HM Woodworking,Inc. Physical Site Address:1903GKN Way City:Newton Zip Code: 28658 County: Catawba Facility Contact: Kevin Hefner Title: President Phone No.: (828)428-2788 Mailing Address:1903GKN Way,Newton,NC28658 Facility Contact Email Address: khefner@hmwoodworkinginc.com Is the facility contact the person that you met? If not,fill out the following: Contact Name: Title: Phone No.: Mailing Address: Email Address: Safety requirements:safety shoes(yes/no)-safety glasses(yes/no)-hearing protection(yes/no)-hardhat(yes/no)- safety vest(yes/no) other(please describe): Normal operating schedule(hr/d,d/wk,wk/yr): 6:30am-2:30 pm;5 days/week(Monday-Friday);50 wee ks/year Opacity(%)-indicate any non-zero opacities observed: 0•1 Odors-indicate if any objectionable odors were detected beyond the property boundary: None Fugitive dust-indicate whetherfugitive dust was observed leaving property boundary: None Since last inspection,have there been any changes in equipment or operation? None Throughput and/orfuel usage with units: Woodwaste(wood chips)-1,724.54tons in 2018;1,482.94tons in 2019; &1,434.88 tons from Jan.1-Oct.31,2020;Wood glue(assembly 433)-35,490lbs in 2018;53,235lbs in 2019&22,815lbs and wood glue (titebond)40 gallons in 2018;75 gallons in 2019&90 gallons from Jan.1-Sept.15,2020 Control device(s)(list): Cyclone(144 inches diameter)installed on woodworking equipment and cyclone (88 inches diameter)installed on grinder Properly operated and maintained? Yes For a permit exempt facility found to be improperly operating or maintaining plant equipment:1)provide compliance assistance as a first option;2)initiate enforcement action in egregious/repeat cases;3)re-evaluate facility's emissions using a more representative control efficiency/emission factor;4)If re-evaluated actual emissions result in a classification/ registration change,follow enforcement guidelines for operation without a permit/registration;and 5)increase compliance visit frequency. Notes or calculation space: Permit Exemption: •Actual emissions from the previous year(s)(and projected actual)of PM10,S02,NOx,VOCs,CO,HAPs,and TAPS are each<5 tpy and whose actual total aggregate of these emissions are<10tpy •Can be subject to 40 CFR Part 63(MACT or GACT)and 40 CFR Part 60(NSPS) •Cannot be subject to Rule 2Q.0315(Synthetic Minor Facilities)or 2Q.0500(Title V Procedures) Woodworking: %each must total 100 Wood waste(tpy):2018-1,724.54tons Planing 2019-1,482.94 tons Sawing/chipping 95Routing 2020-Jan-Oct.1,434.88 Rough sawing SSawing Throughput(board ft/yr): Fine sawing Wet/dry wood? Dry Wood Milling(&hog) 100Grinder Bagfilter or cyclone?Two Cyclones Molding Sanding