HomeMy WebLinkAboutAQ_F_0200072_20200115_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Hancock&Moore,LLC dba Hancock&Moore
Plant 3
Inspection Report NC Facility ID 0200072
Date: 01/15/2020 County/FIPS:Alexander/003
Facility Data Permit Data
Hancock&Moore,LLC dba Hancock&Moore Plant 3 Permit 07535/R08
405 Rink Dam Road Issued 9/19/2017
Hickory,NC 28601 Expires 8/31/2025
Lat: 35d48.9300m Long:8ld 18.1056m Class/Status Small
SIC: 2512/Upholstered Household Furniture Permit Status Active
NAICS: 337121 /Upholstered Household Furniture Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Robert Hatfield Bryan Craft Dennis Tart
Maintenance Supervisor Plant Manager Environmental Engineer
(828)612-8881 (828)578 2867 (828)326-8376
Compliance Data
Comments:
Inspection Date 01/15/2020
Inspector's Name Karyn Kurek
Inspector's Signature: / Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: //2 00 t��� On-Site Inspection Result Compliance.
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2016 15.13 --- 0.1000 3.24 0.0800 8.44 476.67
2011 12.87 --- 0.1100 11.60 0.0900 7.99 1465.02
*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
Hancock&Moore LLC,
dba Hancock&Moore Plant 3
January 15,2020
Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 1/17/2020 _IBEAM WARNING/OB,NOD,NOV,NRE
Tracking: 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 1/1/2022
Directions: From MRO,travel I-77 north to 1-40 west. Take Hwy. 16 exit and travel north on Hwy. 16
toward Taylorsville. Travel approximately 9 miles and turn left onto Friendship Church Road. Travel
approximately 2 miles and turn left onto Church Road. Travel approximately l mile and turn right onto
Rink Dam Road. Travel approximately 4 miles and the facility will be located on the right at 405 Rink
Dam Road.
Safety Equipment: Safety glasses,safety shoes and ear protection are recommended.
Safety Issues: None noted.
Lat/Long Coordinates: A review of the facility's coordinates on DAQ's"Facilities Regulated by Air
Quality"website indicates the facility latitude and longitude coordinates are not listed,however the
location appears to be accurate.No changes to the latitude and longitude coordinates of this facility in
IBEAM are needed.
Email Contacts: IBEAM email contacts were reviewed and Mr. Robert Hatfield,Maintenance
Supervisor,was updated as the Facility Contact.
1. The purpose of this site visit was to conduct a routine air quality inspection.This facility
manufactures upholstered furniture.The facility is currently operating forty hours per week, 50
weeks per year.The facility employs approximately 400 employees between Plant 1 &Plant 3.1
arrived at the facility on January 15,2020 at approximately 9:30 AM.Mr. Robert Hatfield,
Maintenance Supervisor, accompanied me during this inspection.
2.. Facility Contact Information:
IBEAM email contacts were reviewed and Mr.Robert Hatfield,Maintenance Supervisor,was
updated as the Facility Contact.
3. Compliance history file review:
No problems have been noted in the last five years by DAQ, prior to this inspection. The current
compliance status is discussed in the following sections.
Hancock&Moore LLC,
dba Hancock&Moore Plant 3
January 15,2020
Page 3
4. Observations of permitted air emission sources and control devices:
a.
Emission Emission Source Control Control System,
Source ID Description System ID'�Description
SB-1, SB-2, SB-3 three(3) dry-filter type paint spray
booths installed on a furniture spray N/A N/A
painting operation
Observed. One of the three,spray booths were observed in operation with no visible
emissions. The booths are equipped with air flow sensors(cfm), which will shut off the
booth fan if there is not adequate air flow through the filters.All booths utilize HVLP
spray guns. Mr. Hatfield stated that the filters are replaced at least once a week.All filters
were in place and appeared to be in good operating condition.
b.
'Emission;
I ; ..Emission Source Control. Control System
i Source Description System ID Description
ID
ES-1 woodworking C-2,C-1 One(1)simple cyclone(ID No. C-1, 12
equipment feet in diameter) installed in series with
one(1)simple cyclone(ID No. C-2, 8.5.
feet in diameter)
IH-1 wood hog C-1 One(1)simple cyclone(ID No. C-1, 12
feet in diameter)
Observed.The facility has installed a new CNC wood cutting machine and plans to install
a second unit. The new unit was observed in operation and is vented through the cyclones.
All the woodworking equipment is vented to cyclone C-1. The collected wood waste is
transferred to a storage bin via cyclone C-2. The wood hog(ID No. H-1) also vents to
cyclone C-2. The facility processes approximately 3500 bd. ft. of lumber per month. The
cyclone is emptied via truck approximately every two weeks. The woodworking
equipment(ES-1), wood hog(H-1), and cyclones (C-1 &C-2)were observed in operation
with no visible emissions or buildup of sawdust around any exhaust points.
5. Observations of insignificant air emission sources and control devices listed on the current
ep rmit:
a.
Exemption Source of Source of
Source Regulation TAPS? Title V
_ - Pollutants?
IB-01 -natural gas/No. 2 fuel oil-fired 2Q .0102 (g)(5)(A) ' Yes Yes
boiler only firing fuel oil during periods
Hancock&Moore LLC,
dba Hancock&Moore Plant 3
January 15,2020
Page 4
Exemption Source of Source of
Source , Title V
Regulation TAPS? ; pollutants?
of natural gas curtailment(4.18 million
!Btu per hour maximum heat input)
Observed.The boiler(Trane— 1973) is used for comfort heat and was not in operation at
the time of this inspection.Mr. Hatfield stated that they have only used natural gas as
fuel, no fuel oil has been used for curtailment at the time of inspection.
b.
Exemption Source of
Source,of
Source Title V
Regulation TAPs? , pollutants?
I-Wash-washoff tank 2Q 0102 (h)(5)---� No No
Observed. The tank was in use and was observed covered when not actively being used.
C.
Exemption Source of Source of
Source Title V
Regulation TAPs? ; pollutants?
�I-Bleach-bleach booth I 2Q .0102 (h)(5) No— I No
Observed. The booth was not in operation at the time of this inspection. Mr. Hatfield
confirmed that the booth is no longer used.
6. Observations of air emission sources and control devices not listed on the current permit:
a. N/A
7. Compliance with specific permit conditions and limitations:
a. Condition A.2 15A NCAC 2Q .0304(d)and (f)"Permit Renewal and Emission
Inventory". The Permittee, at least 90 days prior to the expiration date of this permit,
shall request permit renewal by letter.
Observed. Permit 07535R08 was issued September 19,2017 and does not expire until
August 31,2025.No action is required at this time. Compliance with this stipulation is
indicated. -
b. Condition A.3. 15A NCAC 2D .0512 "Particulates From Wood Products Finishing
Plants". Provide adequate ductwork and properly designed collectors to control
woodworking particulates.
Hancock&Moore LLC,
dba Hancock&Moore Plant 3
January 15, 2020
Page 5
Observed. Wood particulate appeared lobe properly controlled. No sawdust waste was
observed at exhaust points around the cyclones and ductwork appears to be properly
maintained. Compliance,with this stipulation 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 during inspection.
Compliance with this stipulation is indicated.
d. Condition A.5. 15A NCAC 2D .0535. Permittee of a source of excess emissions that last
for more than four hours and that results from a malfunction, a breakdown of process or
control equipment or any other abnormal conditions, shall notify the Director or his
designee of any such occurrence by 9:00 a:m:Eastern time of the Division's next business
day of becoming aware of the occurrence.
Observed. Based on a records review and conversation with Mr. Hatfield,no excess
emissions have occurred at the facility. Compliance with this stipulation is indicated.
e. Condition A.6. 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission
Sources." The Permittee shall not cause or allow fugitive dust emissions to cause or
contribute to substantive complaints or excess visible emissions beyond the property
boundary.
Observed. There have been no complaints received by the MRO regarding the facility
and no fugitive dust emissions were observed at the time of this inspection. Compliance
with this stipulation is indicated.
£ Condition A.7. CYCLONE REQUIREMENTS. Conduct an annual inspection of the
cyclone systems. Perform inspections and maintenance as recommended by the '
equipment manufacturer and list corrections made and dates of actions in a cyclone
logbook.
Observed. The facility conducts monthly inspections of the wood waste collection
system and maintains records of the inspections.The logbook is located in the wood
working area at a desk on the shop floor, past the spray booths. In addition, a weekly
observation is conducted, and records are maintained. The most recent monthly
inspection was conducted on December 19,2019. Compliance with this stipulation is
indicated.
g. Condition A.8. 15A NCAC 2D .1806 "Control and Prohibition of Odorous Emissions"
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.
Hancock&Moore LLC,
dba Hancock&Moore Plant 3
January 15,2020
Page 6
Observed. No odors were detected inside or outside the plant during the time of
inspection. Compliance with this stipulation is indicated.
h. Condition A.9"Avoidance of NESHAP 40 CFR 63 Subpart 6J)"The Permittee is subject
to this subpart if they own or operate an industrial, commercial, or institutional boiler that
is located at, or is part of, an area source of hazardous air pollutants (HAP). The
Permittee has agreed to only burn oil during periods of natural gas curtailment or
maintenance to avoid being subject to this requirement.
Observed.The facility boiler(Insignificant ID No. 1B-01; natural gas/No. 2 fuel-oil
fired, 4.18 MMBtu/hr.) is subject to the Subpart 6J Boiler MACT. In order to avoid
being subject to NESHAP Subpart JJJJJJ the facility has agreed to only burn fuel oil
during periods of natural gas curtailment or maintenance. The facility must keep records
of fuel oil burned and the reason for burning it. The facility has only used natural gas,no
fuel oil has been used for curtailment. Compliance with this stipulation is indicated.
8. NSPS/NESHAP Review
a. The facility was sent a letter on November 13, 2007 regarding Subpart 000000
"Flexible Polyurethane Foam Manufacturing." The facility does not conduct any type of
foam manufacturing or fabrication and therefore is not subject to the referenced subpart.
b. The facility boiler(Insignificant ID No. IB-01; natural gas/No. 2 fuel-oil fired,4.18
MMBtu/hr.) is subject to the Subpart 6J Boiler MACT. In order to avoid being subject to
NESHAP Subpart JJJJJJ the facility has agreed to only burn fuel oil during periods of
natural gas curtailment or maintenance. The facility must keep records of fuel oil burned
and the reason for burning it. The facility has only used natural gas, no fuel oil has been
used for curtailment.Therefore,this facility appears to be in compliance.
c. There are no emergency generators and the fire pump on site onsite is electric,therefore the
facility is not subject to NESHAP 4Z.
d. The facility does not have any gasoline storage tanks onsite,therefore, it is not subject to
NESHAP 6C.
9. Summary of changes needed to the current permit:
None.
10. Compliance assistance offered duringthe he inspection:
The facility has installed a new CNC wood cutting machine and plans to install a second unit.The
new unit was observed in operation and is vented through the cyclones.I informed Mr.Hatfield
and later Mr. Dennis Tart, Environmental Engineer for the facility,that prior to installing the new
CNC they should notify our offices. I received an email following this inspection from Mr.
Dennis Tart with the current CNC machine specs;these were reviewed by Jennifer Womick,
permit coordinator of this office. She determined that the new CNC machine would be covered
Hancock&Moore LLC,
dba Hancock&'Moore Plant 3
January 15, 2020
Page 7
under the current permit description of"wood working equipment". A copy,of the email and
attachment are below:
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Karyn: i
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Regarding the wood working equipment changes at the Hancock 8,
Moore-Plant 3 we briefly discussed this morning, please find the
attached letter from Howard Martin. If you need any additional
information regarding either HM Plant 1 or HM Plant 3, please let me
know. Thanks.
Dennis Tart
Environmental Engineer
828-326-8376/828-855-5521 cell
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Home Tools � HId plant 3-Letter-.x O
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C ENTURY FURNITURE l
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January 15.20?0
Dennis'1'mt
Environmental Engineer !
Century Furniture.LLC
I
Dear I)e mis. l
j
Per our recent dis,,C—ind,I am writing a,explain Ilse machine roam changes that took pbee at 1 m
Hareuck k Man,c,flans d looted at 405 Rink Dam Read:I:ickoty,NC 28602.
In the Fall 0r2018,the traditional woodworking.paatioas,1—I'd in the bosemem area of
HRM Plan 3,was shut down and emn reed w a plywood apsnalicnn.A a restah,most ofth.
o Iraditional wood w.,king equipment was ran.,ed.leaning only a few' nsple shup'rype s
machlnas used lit the product d-clopmenl ac(i6ims.Addidorlally,a Northwood T.448MT
CNC mule,ens umredint.the vnented Moor area,where it is osal to cut tnrniturc frame parts
ontufply—d.Future plmss irnaude dre addition nfa second Northsvnod TA4RMT CNC muter,
which is.^x[xroted to by hs place b}'Juoc 20'_0.
t
During dm change..1.1
equipment,the only change,ottnrrine to the dust extraction system
uMre to the piping rat the inside of the building only.The duct main sire and f n remain the
same and were not ahemd in any scalp.Thus.the flow rate(efm)proud—d by this dust exlrrction l
system has not changed.
Raspeol'ully subi/rifted,
H.wvrd Martin,PE [
Facilities Engineer
Ccnlury Forniture,LLC
IJ [a
Hancock&Moore LLC,
dba Hancock&Moore Plant 3
January 15, 2020
Page 8
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.
12. Compliance determination:
Based on my observations,this facility appeared to be in compliance with the applicable air
quality regulations at the time of the inspection.
KAK:Ihe
cc:MRO File
https:Hneconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00072/INS PECT_20200115.doc