AQ_F_0200039_20210218_CMPL_CAV-Rpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Daniels Woodcarving Company,Inc.
NC Facility ID 0200039
Inspection Report County/FIPS:Alexander/003
Date: 02/17/2021
Facility Data Permit Data
Daniels Woodcarving Company,Inc. Permit n/a
2325 Highway 90 East Issued n/a
Taylorsville,NC 28681 Expires n/a
Lat: 35d 54.9840m Long: 8ld 8.2410m Class/Status Permit Exempt
SIC: 2511 /Wood Household Furniture Permit Status Inactive
NAILS: 337122/Nonupholstered Wood Household Furniture Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
David Daniels David Daniels David Daniels MACT Part 63: Subpart 6J
CEO CEO CEO
[phone] [phone] [phone]
IL- IL-
Compliance Data
Comments:
k14K Inspection Date 02/17/2021
Inspector's Name Donna Cook
Inspector's Signature: 17oxuta e6ah Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: C211812C21 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2012 0.0300 --- 0.0200 --- 0.0300 0.0200 1.59
2007 0.0300 --- 0.0100 --- 0.0100 0.0300 0.8800
*Highest HAP Emitted in ounds)
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

Daniels Woodcarving Company,Inc.
February 17,2021
Page 2
Type Action: _Full Compliance _Partial Compliance _Complaint X Other: Compliance Assurance Visit
Evaluation Evaluation/Reinspection Investigation C( AV)
Data Tracking: X Date submitted for initial review 02/18/2021 _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 02/01/2023
Directions: From Mooresville Regional Office to Taylorsville,travel via Statesville Avenue;North
Broad Street and the name changes to Statesville Highway(Highway 115 North)and then to Charlotte
Highway(Highway 21 North and Highway 115 North); Interstate 77 North; Exit 51 (Hickory/Winston-
Salem)-Interstate 40 West toward Asheville; off Interstate 40 West take Exit 148-W. Statesville/
Taylorsville US Hwy. 64/NC 90; turn right off exit ramp onto Taylorsville Road US Hwy. 64; 13.2 miles
turn right on Millersville Road; 0.5 mile turn left at the stop sign onto Hwy. 90; and 1.1 miles to this
facility on the right. The street address of this company is 2325 Highway 90 East.
Safety Equipment: This company requires that safety glasses and hearing protection be worn by the
inspector at this facility.
Safety Issues: No safety issues were observed by me during the inspection.
Lat/Long 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 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 and technical contacts were verified by
Mr. David Daniels,chief executive officer of this company. I updated the email address for Mr. Daniels
in IBEAM.
COVID-19 Information:
Mr. David Daniels,chief executive officer of this company, at(828)632-7336, and I discussed the
COVID-19 restrictions at this facility prior to the site visit. Mr. Daniels stated that this company will
allow the inspector on-site if a face covering(mask)is worn and the physical distancing of at least six feet
(social distancing)is maintained from other plant personnel.
Before conducting the inspection, I 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 on-site inspection.
The on-site compliance assurance visit(CAV)inspection was conducted by me inside and outside of the
old and new buildings of this facility. I met with Mr.Daniels outside the entrance to this facility. Mr.
Daniels escorted me inside to the boiler room,woodworking and gluing operations and outside to the two

Daniels Woodcarving Company,Inc.
February 17,2021
Page 3
bagfilter and transfer cyclone. Both Mr. Daniels and I wore a face covering and maintained a distance of
more than six feet(social distancing) from each other and other plant personnel during the CAV.
Compliance Assurance Visit:
1. General Information:
The purpose of this site visit was to conduct a compliance assurance visit (CAV). Daniels
Woodcarving Company, Inc. manufactures wood furniture parts and frames. This company
currently operates this facility 8 to 10 hours per day (40 to 48 hours per week), Monday through
Saturday, 50 weeks per year.
2. Facility Contact Information:
During the inspection, I verified the facility contact information in IBEAM with Mr. Daniels.No
changes to the facility contact information are needed in IBEAM. I updated the email address for
Mr. Daniels 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 company has two bagfilters(6,924 square feet of filter area, each) installed on woodworking
equipment; one closed-loop transfer cyclone; and one seasonal-use biomass(wood-fired)boiler
rated at 2.4 million Btu per hour. These sources were installed after July 1, 1971. The visible
emissions from this facility are limited to 20%opacity when averaged over a six-minute period
as required by 15A NCAC 2D .0521 "Control of Visible Emissions."
The woodworking equipment consisting of various band saws,routers,molders, shapers and
sanders that are vented to the bagfilter(6,924 square feet of filter area)in the old building and to
another bagfilter(6,924 square feet of filter area)in the newer building. Both bagfilters exhaust
to a closed-loop transfer cyclone(size unknown). The woodwaste is dropped through a chute
from the closed-loop cyclone into the first open top tractor trailer and then augered into the
second open top tractor trailer. Mr. Daniels stated that there are augering systems inside of each
tractor trailer. The woodworking equipment,two bagfilters and transfer cyclone were in
operation. I observed no visible emissions from these sources.
The exhaust of each bagfilter is returned through two separate ducts inside of this facility for the
purpose of heating the old and new buildings in colder weather. Both bagfilters exhaust to the
outdoor atmosphere during warmer weather. The stack of one bagfilter is horizontal and
uncapped. The other stack of the second bagfilter is horizontal with louvers. During the CAV,
the two bagfilters were exhausting inside for the purpose of heating the old and new buildings. I
observed no visible emissions from the vent or stack exhausts of each bagfilter located inside
and outside of this facility.
This company uses a wood-fired boiler(manufacturer,Hurst Boiler and Welding Co.,Inc.; mfg.
serial#FB32530; 1725 steam lbs. hr. and 1983,year built)to steam heat this facility. The

Daniels Woodcarving Company,Inc.
February 17,2021
Page 4
maximum heat input of this boiler is rated at 2.4 million Btu per hour. The scrap hardwood
blocks are manually placed inside of the boiler. The wood-fired boiler functions like a fireplace.
There are no burners or system controls on the boiler. A pressure gauge and grates are installed
on this boiler. Mr. Daniels stated that the boiler operates 20 to 30 days per year when the
temperature is below 32 degrees Fahrenheit. The wood-fired boiler is subject to the requirements
of 40 CFR Part 63, Subpart JJJJJJ(6J) "National Emission Standards for Hazardous Air
Pollutants(NESHAP) for Area Sources: Industrial, Commercial, and Institutional Boilers."
During this visit,the wood-fired boiler was in operation with visible emissions ranging from 0%
to 5%opacity. The visible emissions from the wood-fired boiler are not exceeding the 20%
opacity limit when averaged over a six-minute period.
This company uses two wood glues (Assembly High Tack and Assembly 233) by the
manufacturer, Franklin International. The wood glues are applied to the furniture frames and
parts in a horizontal tray. During the CAV, I observed glueing operations being conducted by
plant personnel. No visible emissions were observed or any odors detected by me from the
glueing operations.
This facility is subject to the fugitive dust rule, 15A NCAC 02D .0540. This office has not
received any fugitive dust emissions complaints regarding this facility. This company has paved
roads in the front and unpaved roads in rear of this facility. During this visit,I observed no
fugitive dust from this facility. I discussed with Mr. Daniels if any excess emissions had
occurred at this facility since the last inspection on February 21, 2019. Mr. Daniels stated that no
excess emissions had occurred at this facility.
5. NSPS/NESHAP Review:
The manufacturing of wooden furniture parts and frames is currently not subject to any NSPS
rules. The seasonal biomass (wood-fired)boiler is not subject to 40 CFR Part 60, Subpart Dc-
"Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating
Units,"because the heat input capacity of this boiler is less than 10 million Btu per hour.
The biomass(wood-fired)boiler rated at 2.4 million Btu per hour was built in the year 1983.
This wood-fired boiler is considered an existing source in 40 CFR Part 63, Subpart JJJJJJ or 6J,
"National Emission Standards for Hazardous Air Pollutants(NESHAP) for Area Sources:
Industrial, Commercial, and Institutional Boilers,"because it commenced construction on or
before June 4,2010. The NESHAP Subpart 6J defines a seasonal-use boiler as being shutdown
for a period of at least 7 consecutive months or 210 consecutive days each 12-month period due
to seasonal conditions except for periodic testing. The periodic testing can not exceed a
combined total of 15 days during the 7 month shutdown. The wood-fired boiler meets the
definition of seasonal-use since it operates approximately 20 to 30 days per year and the heat
input is less than or equal to 5 million Btu per hour. This facility is required by NESHAP 6J to
keep days of operation per year for the seasonal boiler. Mr. Daniels stated that the operated 20
days in 2019 and 24 days in 2020.
The initial notification form had to be submitted by January 20,2014. NC DAQ received the
initial notification form on October 10,2011, stating that existing wood-fired boiler(ID No. B-1)
at this facility is subject the NESHAP rule. The notification of compliance status(NOCS)for the
boiler tune-up had to be submitted by July 19, 2014(previous 6J rule deadline dates were July 19,
2012 and July 19, 2013 by USEPA). The NOCS was received by MRO DAQ on May 9,2012.
Copies of these notifications are being kept by this facility.

Daniels Woodcarving Company,Inc.
February 17,2021
Page 5
The one-time energy assessment for boilers with a heat input greater than or equal to 10 million
Btu per hour was due by March 21,2014. The energy assessment requirement does not apply to
this existing boiler since the heat input capacity of this boiler is not 10 million Btu per hour or
greater.
The NESHAP 6J rule does not have emission limits on the existing wood-fired boiler. This
company must implement a tune-up program as a management practice. An initial boiler tune-up
was required by March 21,2014 (previous 6J rule deadline dates were March 21,2012 and
March 21, 2013 by USEPA). The initial tune-up of this boiler was conducted on December
23,2011. This boiler is required by NESHAP Subpart 6J to conduct a tune-up every 5 years or
within 61 months of the previous tune-up.
The boiler operates like a fireplace so the tune-up activities are minimal. There is no burner or
air-fuel ratio to adjust to optimize combustion and no concentrations of carbon monoxide or
oxygen to be measured. Mr. Daniels stated that this boiler is steam heated and the NC
Department of Labor inspects this boiler once every two years in the Spring. According to the
records provided by Mr. Daniels,the tune-ups/inspections of the boiler were conducted on
3/20/18; 3/21/17; 3/24/16; and 11/l/13. The next tune-up inspection should be conducted by
March 2023. Mr. Daniels stated that wood-fired boiler will be inspected by the NC Department
of Labor next month.
This company must prepare a compliance certification report by March 1 every five years,
maintain it on site unless specifically requested by NC DAQ, and then subsequent certifications
prepared by March 1 of the year following the boiler tune-up. The compliance certification
reports provided by Mr. Daniels were dated 3/20/18; 3/21/17; 3/24/16; and 11/l/13. The boiler
tune-up/inspection records are being maintained on-site at this facility. If the wood-fired boiler
experiences any deviations from the applicable requirements,then the compliance certification
report must be submitted by March 15 of the year following the boiler tune-up. Mr. Daniels
stated that the wood-fired boiler has not experienced any deviations. I reminded Mr. Daniels to
prepare the compliance certification report by March 1 of the year following the boiler tune-up
and submit to MRO DAQ if the wood-fired boiler experiences any deviations.
This company has no emergency or peak shaving generators, fire pump engines or gasoline
storage tanks at this facility.
6. Exemption Qualification:
On October 17,2016,this office received a request from this company to rescind Air Permit No.
05446R09, since the actual facility-wide emissions of particulate matter(PM 10), 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.
This company provided information with the permit rescission request on the actual facility-wide
emissions from the wood-fired boiler and woodworking equipment for calendar years 2011 through
2015 to verify the exemption. The highest wood usage from the boiler was 6 tons. The highest
board feet from the woodworking operations was 680,000. The actual emissions from the wood
combustion and woodworking operations were calculated by MRO DAQ permitting using the
NCDEQ DAQ Woodwaste Combustion Emissions Calculator Revision J and Woodworking

Daniels Woodcarving Company,Inc.
February 17,2021
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Emissions Calculator Revision C July 2007. The pollutants and actual emissions from the wood
combustion and woodworking operations for 2011 through 2015 calendar years are listed in the
below table:
Pollutant 2015 Actual 2014 Actual 2013 Actual 2012 Actual 2011 Actual
Emissions Emissions Emissions Emissions Emissions
t t t
Wood Combustion and Woodworking Operations
PM10 0.060 0.060 1 0.060 1 0.050 0.050
SO2 0,011 0.0 11 0,_011 0.0 11 0.0
NOx 0.020 1 0.020 1 0.020 1 0.020 11 0.020
VOC 0,011 0.0 11 0,_011 0.0 11 0.0
CO 0.030 0.030 0.020 0.030 0.030
Total HAP 1 0.0019 0.0020 0.0015 0.0016 0.0019
Total 0.11 0.11 0.10 0.10 0.10
Aggregate
The glueing operations were listed in the Air Permit No. 05446R09 as an insignificant/exempt
activity and not evaluated during the permit recession request. The glues,Assembly High Tack and
Assembly,manufactured by Franklin International contain negligible VOC and HAP emissions. The
Safety Data Sheets(SDS)indicate that the Assembly High Tack glue has 0.089 pounds per gallon of
VOC and Assembly 233 glue has 0.0196 pounds per gallon of VOC. Based on the SDS,the actual
emissions from the glueing operations are less than five tons per year and exempt from permitting
per 15A NCAC 2Q .0102 (h)(3).
This office sent a letter dated November 4,2016 to this company exempting this facility from
permitting, since the facility-wide actual 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 per 15A NCAC 2Q .0102 (d) and
recession of the air permit.
Mr. Daniels provided the board feet of lumber;pounds of wood combusted and pounds of glue
applied for 2019 and 2020 calendar years. The board feet of lumber from the woodworking
operations was 702,000 in 2019 and 560,000 in 2020. The wood combusted in the boiler was 10
pounds in 2019 and 12 pounds in 2020. The wood glues applied to furniture frames and parts
were 3,250 pounds in 2019 and 4,025 pounds in 2020 for the Assembly High Tack brand and
9,700 pounds in 2019 and 12,125 pounds in 2020 for the Assembly 233 brand. The actual
emissions from the woodworking operations,wood combustion and glueing operations are below
the exemption thresholds. The actual facility-wide emissions of all pollutants 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 permit
exemption and recession request.
7. Compliance determination:
Based on my observations, this facility appeared to be in compliance with the air quality rules
(213 .0521-visible emissions; 2D .0535-excess emissions; 2D .0540-fugitive dust emissions; 02D

Daniels Woodcarving Company,Inc.
February 17,2021
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.1806-odorous emissions; and 2D .1111 Maximum Achievable Control Technology (MALT) as
promulgated in 40 CFR Part 63, Subpart JJJJJJ (0), NESHAP for area sources or boiler GACT
6J at the time of the visit. The compliance assurance visit checklist is attached on page 8.
DLC:
c: MRO File
https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00039/INSPECT 20210217_CAV.docx

Daniels Woodcarving Company,Inc.
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Compliance Assurance Visit Checklist rev.11/03/16
Facility Name: Daniels Woodcarving Company,Inc.
Physical Site Address: 2325 Highway 90 East
City: Taylorsville Zip Code: 28681 County: Alexander
Facility Contact: David Daniels Title: Chief Executive Officer
Phone No.:[phone]
Mailing Address:2325 Highway 90 East,Tyalorsville,NC 28681
Facility Contact Email Address: [e-mail]
Is the facility contact the person that you met? If not,fill out the following:
Contact Name: Same 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): 8-9 hr/d or40-48 hr/wk,6 d/wk,50 wk/yr
Opacity(%)-indicate any non-zero opacities observed: 0%from woodworking&0-5%from wood-fired boiler
Odors-indicate if any objectionable odors were detected beyond the property boundary: None
Fugitive dust-indicate whether fugitive 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: Woodworking:CY 2020=560,000 board feet;CY 2019=702,000 board feet;
Wood-fired boiler:CY 2020=12 pounds;CY 2019=30 pounds
Control device(s)(list): Two bagfilters(6,924 square feet of filter area,each)installed on woodworking
equipment;Transfercyclone(size unknown)installed on both bagfilters
Properly operated and maintained? Yes
Fora 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:
Other Sources: Seasonal-use wood-fired boiler that produces steam(2.4 million Btu per hour heat input rate)for comfort
heating;Franklin International glue usage:Assembly High Tack CY 2020=4,025 pounds&CY 2019=3,250 pounds and
Assembly 233 CY 2020=12,125 pounds&CY 2019=9,700 pounds
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)
Boilers:
ID No. #1 #2 #3 44
Installed or last modified date 1983 built
Size(mmBTU heat input) 2.4million Btu/hrinput
Primary/backup fuel: Wood
Fuel used(annual) 10-12 pounds
NSPS Subpart Dc subject? No<10 million Btu/hr input
NSPS Subpart Dc boiler if>10 mmBtu/hr and<100 mmBtu/hr installed or modified after June 9,1989.
Gas only Dc subject boilers:have they submitted initial notification(only requirement)? Yes/No/NA
Gas/fuel oil Dc subject boilers:records kept of each fuel type and startup notification for each fuel? Yes/No/NA
Fuel oil certification required for Dc subject boilers(0.5%max S content). Are copies kept? Yes/No/NA
If fuel oil Dc subject boiler>30 mmBtu/hr,was opacity testing performed on schedule based on results?' Yes/No/NA
2If VE=O%then done annually,<=5%done semiannually,<=30%done quarterly,>10%done every 45 days.
GACT61 Gas Curtailment option claimed? Yes/No
If no,has a one-time energy assessment been performed. Yes/No/NA
If no,are tune-ups being done biennially(25 months since last tune-up)? Yes/No/NA
If yes,are records kept for natural gas curtailment and testing less than 48 hours per year. Yes/No/NA
Woodworking: %each must total 100
Wood waste(tpy): Planing
or Sawing/chipping 70
Throughput(board ft/yr): CY 2020=560,000 bd.ft. Rough sawing
CY 2019=702,000 bd.ft. Fine sawing
Wet/dry wood? Dry Wood Milling(&hog)
Bagfilter or cyclone? Bagfilters(6,924sgft,each) Molding
Transfer cyclone(size unknown) Sanding 30