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Home My WebLink AboutAQ_F_0300015_20191217_CMPL_InspRpt NORTH CAROLINA DIVISION OF Winston-Salem Regional Office AIR QUALITY International Pipes and Accessories LLC NC Facility ID 0300015 Inspection Report County/FIPS: Alleghany/005 Date: 12/18/2019 Facility Data Permit Data International Pipes and Accessories LLC Permit 04288/R13 1731 US Highway 21 South Issued 3/20/2018 Sparta,NC 28675 Expires 2/28/2026 Lat: 36d 29.3460m Long: 8 1 d 5.9280m Class/Status Small SIC: 2141 /Tobacco Stemming and Redrying Permit Status Active NAICS: 312229/Other Tobacco Product Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Rick Wooten Rick Wooten Denise Osborne MACT Part 63: Subpart 6.1 Plant Manager Plant Manager (336)372-5521 (336)372-5521 (336)372-5521 Compliance Data Comments: Inspection Date 12/17/2019 Inspector's Name Ryan Dyson Inspector's Signature: Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: MTH On-Site Inspection Result Compliance 12,2DJ2o1cl Total Actual emissions in TONS/YEAR: TSP SO2 NOX VOC CO PMIO * HAP 2016 0.4200 0.1600 0.0400 0.8730 0.0100 0.4100 1029.94 2012 0.6200 0.2600 0.0700 1.35 0.0150 0.6200 1464.62 * Highest HAP Emitted inpounds) 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 1 Permitted Sources Emission Source ID Emission Source Description Control System ID Control System Description ._. ......... ......... .»......._. .....__......_ _.._ .W.:�...�..�....._. ......... ._..._.._..»........_._ .»_.._ ._...._ . CD-1 Ba filter(3,240 square feet of filter area ES-1 Wood working operation F CD-2 ;Bagfilter(3,240 square feet of filter area) CD-3 Ba_filter(3,840 square feet of filter area .............................. g ( � q ) ..................................................................................................................................................................................................................................... FC-1, FC-2 ' Two flow coaters N/A N/A One pipe finishing operation,consisting of: ..................................................................................................................................................................................................................................................................................................................................................._......:..:...................................................:.:..._.....................:...:.:.............................................................................:, CL-1 Charcoal lining machine N/A N/A ...................................................................................................... ........................................................................................................................................................... ................................................................................................................._............................._._..........._..........................................._........._......_......._.............................................. SB-1 Dry filter-type spray booth N/A N/A DR-1 Electrically-heated drying room �N/A N/A .................................................................................................._..... f- Electrical_........ ... .......... ..................... .................._._...................................................................... ..... ........._.... ......._....._...................... ..._..............._....._.._..._.m_._........_..:._.....m..._.__..........._...:: ....T..........._...�.................. .......... __ ._._.:.:.....__.._....T..... ..... ........ .__...._... DO-1 ly-heated drying oven N/A N/A Insignificant/Exempt Activities Exemption Source of Source of Title V Source Regulation TAPs? Pollutants? E :IES-1 - Propane gas/No. 2 fuel oil-fired boiler 2Q .0102 (h)(1)(A) Yes Yes (6.277 million Btu per hour maximum capacity) :IES-3 -Aboveground, 10,000 gallon No. 2 fuel oil storage tank 2Q .0102 (g)(4) T Yes Yes Y..................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................�................................................................_......... :IES-4 - Aboveground, 1,000 gallon propane storage tank 2Q .0102 (g)(4) No Yes IES-5 -Aboveground, 250 gallon propane storage tank 2Q .0102 (g)(4) No Yes ........_....................................................................................................................................................................................._.........................................................................._.._......._._._.....___.............................._........................................................... .............................._.__.....__..,_...._._......_W........................... .._.._...._._ ... .W._.__....... IES-6-Parts washer 2Q .0102 (h)(3) Yes Yes Introduction On December 17, 2019, Mr. Ryan Dyson, Environmental Specialist for the Winston-Salem Regional Office of the North Carolina Division of Air Quality(WSRO-DAQ), and Mr. Matt Harper, Environmental Engineer for the WSRO-DAQ, conducted an unannounced compliance inspection of International Pipes and Accessories LLC. This facility was last inspected by Mr. Paul Williams, fonner Environmental Specialist for the WSRO-DAQ, on November 6, 2017 and was found to be operating in compliance with all applicable Air Quality standards and regulations at the time of inspection. Mr. Rick Wooten, Plant Manager, was unavailable at the time of inspection. Mr. Kenny Mount, Maintenance Manager, assisted with the inspection in Mr. Wooten's absence. The FacFinder contact information for this facility was confirmed by Mr. Mount. The facility manufactures wooden tobacco smoking pipes, with confirmed operating hours of 6:30 AM to 5:00 PM, Monday through Thursday, for 49 weeks per year. Mr. Mount indicated that production is declining,and there have been no process or equipment changes since the last inspection. Safety Equipment Proper Personal Protective Equipment(PPE) for this facility includes safety glasses and hearing protection. Applicable Regulations Permit Condition A.1 states that the facility is subject to the following regulations: Title 15A North Carolina Administrative Code(NCAC), Subchapter 2D .0202, 2D .0512, 2D .0521, 2D .0535, 2D .0540, 2D .0611, and 2D .1806. This facility is not subject to the Risk Management Plan (RMP)requirements of the 112(r)Program, as it does not purchase, produce, utilize or store any of the regulated substances in quantities above their associated threshold limits. The facility is still subject to the General Duty clause in this rule. Discussion This facility manufactures wooden tobacco smoking pipes that are sold under the Dr. Grabow brand name. The process begins as the facility receives shipments of briar wood in burlap bags from Greece and Italy. The briar wood arrives in 2 block pieces that are then manually inspected and sorted based on size. Following this step,the blocks are shaped into specific pipe models using a wide assortment of specialized woodworking equipment(ES-1) for boring, trimming, detailing and fine sanding. The emissions from the woodworking operation are controlled by bagfilter unit CD-3. At the time of inspection, only the touch-up/final detailing portion of the process appeared to be in operation. Bagfilter CD-3 was also observed in operation,with all ductwork appearing to be maintained in proper working order, and no discernible visible emissions. The facility is also permitted for two other bagfilter units(CD-1 and CD-2). However, as confirmed from Mr. Williams' prior inspection report, these units have been taken out of service due to a decrease in production and reduction of process equipment over the years. All current woodworking process equipment is routed through bagfilter CD-3. The facility is permitted for two flow coaters(FC-1 and FC-2). These coaters would be utilized to apply stain to the pipes. One flow coater coats the pipe, while the other is intended to clean off any excessive stain residue. Both were observed on-site, however Mr. Mount stated that the flow coater used to remove excess stain hasn't been used in several years, and the flow coater used to apply stain is typically in operation for approximately one hour a week. The facility is also permitted for a charcoal lining machine(CL-1), a dry filter-type spray booth (SB-1), an electrically heated drying room (DR-1) and an electrically heated drying oven (DO-1). All this equipment was observed on-site, however none of it was in operation at the time of inspection. The charcoal lining machine, which would be utilized to spray a charcoal-based substance into the bowl of the pipe is no longer operational, as it has been partially deconstructed. The filters for the spray booth appeared to be in proper working order at the time of the inspection, with no discernible gaps or holes. Mr. Mount estimated that this spray booth is only in operation for approximately one hour per week. Nonetheless,the filters are cleaned approximately once per month and replaced semi-annually. Mr. Mount also implied that the drying room and oven have not been in operation for several years. The facility operates several exempt sources, including a propane gas/No. 2 fuel oil-fired boiler(6.277 million Btu per hour maximum capacity)(IES-1), a 10,000 gallon aboveground No. 2 fuel oil storage tank(IES-3), a 1,000 gallon aboveground propane storage tank(IES-4), a 250 gallon aboveground propane storage tank(IES-5) and a parts washer (IES-6). Mr. Mount confirmed that the boiler is used solely for comfort heating, and that the propane is only used for assistance in start-up.No. 2 fuel oil is used for combustion following start-up. The boiler was observed in operation at the time of inspection. It was operating at 20 pounds of steam pressure, and a water temperature of 175 degrees Fahrenheit. The Btu value was confirmed from the boiler plate at the time of inspection. All fuel storage tanks were observed on-site, with no signs of leaks or vapor emissions. The parts washer was observed on-site; however, it was not in operation at the time of inspection. Mr. Mount stated that the facility currently uses hot water and baking soda in the washer to clean parts. Permit Conditions Condition A.2 contains the permit renewal and emission inventory requirement of 15A NCAC 2D .0202. To meet this requirement,the facility must submit a permit renewal request and air pollution emission inventory report for the 2024 calendar year at least 90 days prior to the expiration date of the permit. The current permit for this facility expires February 28, 2026. This condition was discussed with Mr. Mount. Compliance with this condition is anticipated. Condition A.3 contains the particulate control requirement of 15A NCAC 2D .0512, "Particulates from Wood Products Finishing Plants."To comply with this condition,the facility must not discharge particulate matter stemming from the working, sanding, or finishing of wood without providing for its collection, adequate duct work and properly designed collectors. All ductwork appeared to be maintained in proper working order at the time of inspection. Compliance with this condition is indicated. Condition A.4 contains the visible emissions control requirement of 15A NCAC 2D .0521. Visible emissions from emission sources manufactured after July 1, 1971 shall not exceed 20 percent opacity when averaged over a six-minute period, except that six-minute periods averaging not more than 87 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour period.No visible emissions were observed at the facility at the time of inspection. Compliance with this condition is indicated. 3 Condition A.5 contains the notification requirement of 15A NCAC 2D .0535. To comply with this condition,the facility shall notify the Director of any excess emissions that last for more than four hours and that result from any malfunction, breakdown of process or control equipment, or any other abnormal circumstance. Mr. Mount stated that there have been no such occurrences at the facility since the date of the last inspection. Compliance with this condition is indicated. Condition A.6 contains the fugitive dust control requirement of 15A NCAC 2D .0540. To comply with this condition,the permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantiated complaints or excess visible emissions beyond the property boundary.No fugitive dust was observed at the time of the inspection, and there is no dust complaint history for this facility in IBEAM. Mr. Mount stated that no dust complaints were received by the facility itself either. Compliance with this condition is indicated. Condition A.7 contains the fabric filter requirements of 15A NCAC 2D .0611. To comply with this condition,the facility shall perform, at a minimum, an annual(for each 12-month period following the initial inspection) internal inspection of each particulate collection device system. Records of these inspections must be kept on-site.Mr. Mount stated that internal inspections of the connected bagfilter unit(CD-3)occur during scheduled shutdowns in July and December of each year. The overarching recorded history of internal inspections presented to Mr. Dyson at the time of inspection indicated that this is largely evident. However,the last documented internal inspection on-file at the time of inspection occurred on December 19,2018. Mr. Mount stated that an internal inspection occurred in July of 2019 and was transparent in admitting that he forgot to document that specific inspection. Mr. Mount stated that they have a planned shutdown occurring at the end of the week(beginning around December 19,2019), and an internal inspection is planned for that time. Mr. Dyson requested that Mr. Mount send a copy of this impending inspection record to him to demonstrate compliance. The existing records appeared to be thorough, with documentation to demonstrate that the bags are checked for structural integrity and dust leaks,that all mechanical aspects are properly lubricated, and that all associated ductwork is inspected as well. Records were reviewed back to the date of Mr. Williams' inspection,with the most recent documented dates being December 19, 2018 and July 19,2018. After this inspection, Mr. Dyson did receive an emailed copy of the internal inspection performed on December 19, 2019. Compliance with this condition is indicated. Condition A.8 contains the control and prohibition of odorous emissions requirement of 15A NCAC 2D .1806. To comply with this condition,the permittee must operate the facility in such a manner as to prevent odorous emissions from causing or contributing to objectionable odors beyond the property boundary.No discernible odors were detected during the approach to the facility, and there is no history of odor complaints in IBEAM pertaining to this facility. Mr. Mount stated that the facility had not received any direct odor complaints either. Compliance with this condition is indicated. NSPS/NESHAP Condition A.9 pertains to the Federal Rule Applicable to Sources Exempted from Air Permitting Requirements. The facility's Propane gas/No. 2 fuel oil-fired boiler(6.277 million Btu per hour maximum capacity)(IES-1) is subject to 40 CFR 63-NESHAP Subpart JJJJJJ. The WSRO-DAQ received an initial notification form from this facility on December 7, 2011. The initial tune up was performed on March 19,2012, and the required Notification of Compliance Status was received by the WSRO-DAQ on March 21, 2012. To comply with this subpart,the facility must conduct biennial tune ups on IES-1. The facility must also maintain records of the notifications,tune ups, and any malfunctions or abnormalities. Mr. Mount stated that annual tune ups are performed on this boiler. Records were reviewed back to the date of the last inspection, with the most recent tune ups occurring on November 8, 2019 and December 19, 2018. The facility contracts the boiler tune ups to a company named CC Boiler. The tune up records appeared to be through. For instance,the records indicated that during the most recent tune up,the fuel oil block was rebuilt(including the regulator,metering stem and packing, and backpressure nozzle),the regulator bearing was cleaned, pressure gauges replaced, and a combustion analysis was conducted with records of the results. Compliance with this condition is indicated. Facility-Wide Emissions The following table,taken from the facility's most recent Application Review, R13, written by Ms. Taylor Hartsfield, WSRO-DAQ Compliance Supervisor, contains the facility's potential and actual emissions for the 2016 calendar year. 4 Actual Emissions [tons/year] Potential Emissions [tons/year] Pollutant _ _.. _._.._._..... _ .. (CY2016) E without controls or limits with controls and limits ....................... ..._............. ...................................................... ..................... ...........................................................::.:: .....:::............................................... ...... PMI_o µ_ 0.41 _ �._......_.�._�...�....�.....�.... 88 _ �" 2.8 _ NO. 0.04 .................. .......... ................_......................................................._._.........__............_..........._._......_.......................................:_............._..........................._............._._.._........._...._.._....................................................._..........._............_._............................__._..............__._........................._........................._............__..._....... _ _ 3.9 3.9 CO _ ._._...0.01 � 2.3 2.3�._ VOC 0.87 7.3 7.3 M....._............... ........__........__......_....................................__............................_........._....._......_......................................................._................................._................_ ................................_...........:............................._......__............................................. HAPTMI 0.60 5.2 5.2 PHighest(Methanol) �.µ.�..µmµ`��µ.:......�._. 0.51 � 3.9 �.. .,,...�..._._.._�.__3.9 Permit Issues/Considerations There do not appear to be any permit issues/considerations associated with this facility at the time of this inspection. Stack Testing No stack testing has ever been conducted at this facility. 5 Year Compliance History This facility has not been issued a NOD,NOV, or NOV/RE in the past 5 years. Conclusion Based on visual observations and record review,International Pipes and Accessories LLC appeared to be operating in compliance with all applicable Air Quality standards and regulations at the time of this inspection. 5