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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: Mesage • ( Ea Reply 1.-1 Duke Buck ��t Reply All U' jE+To Manager ,{�d Delete Archive Atw'e 'Tags lEdi[ing'Sparh.Zggm Insights �� rw Foard I]- l�Team Email Delete Respond (7ulck Steps dove Zaom QM D_nriisM Tart<Deny -i ar.Cwc=ntundwni;ure.corts ol:u;<ti.errs z; •t- fel t wea�Ssm _ [External]Ft¢Letter about H&M Plant 3 Dust Systern It these are probleats v.Ith halo this message is displared,dkk here to view a In :,,b brovlier. v U H&bl Plant 3.Levu C.ncenting the Dust System flan'20j.pcif_ 48 KB --. fxtema smeiot edit irsks orfop.-n at ach is unlesiyau verlry.5endets."kaucme'asan attachme:stop h' . 1 Karyn: i 4 ! 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 X Eee Eda y�er. vines hlep_ _ Home Tools � HId plant 3-Letter-.x O Q C ENTURY FURNITURE l I 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