HomeMy WebLinkAboutAQ_F_0200034_20190730_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Hancock&Moore,LLC dba Hancock&
Moore Plant 2
Inspection Report NC Facility ID 0200034
Date: 07/09/2019 Coun /FIPS: Alexander/003
Facility Data. Permit Data
Hancock&Moore,LLC dba Hancock&Moore Plant 2 Permit 02757/R13
165 Matheson Park Avenue Issued 12/31/2015
Taylorsville,NC 28681 Expires 6/30/2023
Lat: 35d 54.9186m Long: 81d 10.5594m Class/Status Small
SIC: 2512/Upholstered Household Furniture Permit Status Active
NAILS: 337121 /Upholstered Household Furniture Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact
SIP
Dennis Lockhart Andrew Coffey Joy Bailey MACT Part 63: Subpart 6J
Plant Manager Controller Purchasing/Safety/Envi
(828)217-3439 (828)495-8235 ronmental
828 495-8235
Compliance Data
Comments:
Inspection Date 07/09/201.9
Inspector's Name Alejandra Cruz
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2014 15.88 0.0500 0.9300 0.0300 1.14 11.74 71.90
2009 9.30 0.0300 0.5000 0.0200 0.6100 6.87 92.72
* Highest HAP Emitted fin 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
Hancock&Moore Plant 2
July 09,2019
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[Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 7/16/2019 _IBEAM WARNING/OB,NOD,NOV,NRE
Tracking: X IBEAM Document
X 'IBEAM Inspection, list date inspected 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 7/1/21
Directions: From MRO,travel I-77 north to I-40 west,take exit 148 and travel west on Hwy. 64 to
Taylorsville.From highway 64 take the highway 16 north exit and travel approximately 1 mile and turn
right onto Matheson Park Avenue. The facility is the white building sitting lower and to the right and
lower than Matheson Park Ave.The entrance to the facility is just right of the address numbers"165"on
the building.
Safety Equipment. Safety glasses, safety shoes, and ear protection are required.
Safety Issues:None noted.
Lat/Long: "The DAQ Map of Regulated Facilities system is currently not available. According to last
year's inspection report the coordinates were correct. Coordinates in IBEAM are correct and not locked."
Email Contacts: Email contacts found in IBEAM were verified.No changes are needed at this time.
1. The purpose of this site visit was to conduct a routine air quality inspection. We arrived at the .
facility on July 9, 2019 around 2:00 pm. This facility manufactures wooden furniture frames. The
facility is currently operating forty hours per week. Mr.Ryan Mills of the MRO DAQ coinspected.
the facility with me. Mr.Perry Miller accompanied us during this inspection.
2. Facility Contact Information:
During the inspection,I verified the facility contact information in IBEAM.No changes are needed
at this time.
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 Plant 2
July 09,2019
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4. Observations of permitted air emission sources and control devices:
Emission Emission Source Control Control System
Source ID Descri tion System ID Description
- p
1 (NESI3AP) wood-fired boiler(1.6
million Btu per hour N/A N/A
maximum heat input)
Observed.The listed wood fired boiler was removed and replaced with a natural gas burning unit.A letter
postmarked March 1, 2016 was received by this office from Hancock & Moore stating these changes.:
These changes have been listed on the electronic yellow-sheet. 1
Emission Emission Source Control Control System
Source ID Description System ID_ Description
W-1 woodworking operation CD-2 cyclone(114 inches in
_ diameter)
Observed.Observed in operation with no visible emissions or dust accumulation.
{Emission Emission Source Control Control System
Source ID Description System ID Description,
W-2 ]woodworking operation CD-3 cyclone(114 inches in
diameter)
Observed. Observed in operation with no visible emissions or dust accumulation.
Emission Emission Source Control Control System
Source ID ]Description_ System ID — Description
W-3 woodworking operation CD-4, CD-5, CD-6 cyclone(40 inches in
diameter, ID No. CD-4),
dynavane(three single
cells, ID No. CD-5), and
bagfilter(85 square feet
of filter area,ID No.
CD-6), installed in series,
Observed. Observed in operation with no visible emissions or dust accumulation.
5. Observations of insignificant air emission sources and control devices:
Source Exemption Source of Source of Title V
Regulation TAPS? Pollutants?
IEerationood gluing 2Q .0102 (c)(2)(D)(i) . No No
_p
Observed. Observed in operation with no visible emissions,and no odors detected.
Hancock&Moore Plant 2
July 09,2019
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6. Observations of air emission sources and control devices not listed on the current permit:
a. A new gas fired boiler was installed at the beginning of 2016. The new unit is a Cleaver
Brooks, model number CB 200-236-150 and Serial No AN707061. This 9,875,125
Btu/Hr. unit was built in 1999, but it was put into service 9/21/2010. The boiler has an
operational max psi rating of 150. The unit was observed in operation without any visible
emissions. A letter postmarked March 1, 2016 was received by this office from Hancock
&Moore stating these changes. These changes have been listed on the electronic yellow-
sheet.
7. Compliance with specific permit conditions and limitations:
a. Condition A.2. 15A NCAC 2D .0202 "Permit Renewal and Emission Inventory
Requirement". The Permittee, at least 90 days prior to the expiration date of this permit,
shall request permit renewal by letter. The report shall be submitted to the Regional
Supervisor,DAQ and shall document air pollutants emitted for the 2022 calendar year.
Observed. Permit does not expire until 06/30/2023. Compliance is indicated.
b. Condition A.3. 15A NCAC 2D .0504 "Particulates from Wood Burning Indirect Heat
Exchangers".Particulate matter emissions from the wood burning indirect heat exchangers
shall not exceed the allowable emission rate of 1.05 lbs/million Btu
Observed. This condition doesn't apply anymore. The wood fired boiler has been removed from
the facility, and it has been replaced for a natural gas boiler. A letter postmarked March 1,
2016 was received by this office from Hancock & Moore stating these changes. This
condition should be removed from the permit when the boiler is removed from the
equipment. These changes have been listed on the electronic yellow-sheet.
C. Condition A.4. 15A NCAC 2D .0512 "Particulates from Wood Products Finishing
Plants". Permittee shall not discharge particulate matter and shall provide adequate duct
work and properly designed collectors.
Observed. The cyclones, bag house, and Dynavane appeared to be properly maintained.
Wood particulate appeared to be properly maintained. Compliance is indicated.
d. Condition A.5. 15A NCAC 2D .0516 "Sulfur Dioxide Emissions from Combustion
Sources," sulfur dioxide emissions from the combustion sources shall not exceed 2.3
pounds per million Btu heat input.
Observed. The wood fired boiler(ID No. 1)is the only source on the permitted equipment
list subject to this regulation. However, that boiler is no longer located at the facility and
should be removed from the equipment list during the next permit revision.In addition,the
facility has been operating a natural gas fired boiler since 2016 (9.88 million Btu per hour
maximum heat input rating), which will be added to the exempt list of sources during the
next permit revision.Per MRO memo"21) .0516 analysis"dated 04/10/97, compliance the
sulfur limit is assumed for natural gas fired sources.Although this boiler is subject to 02D
.0516, conditions that apply only to exempt sources are not listed in the permit. Therefore,
this condition should be removed from the permit when the wood fired boiler is removed
from the equipment list.
Hancock&Moore Plant 2
July 09, 2019
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e. Condition A.6. 15A NCAC 2D .0521 "Control of Visible Emissions".Visible emissions
from woodworking operation (ID No. W-1), woodworking operation (ID No. W-2), and
woodworking operation(ID No. W-3)shall not be more than 20 percent opacity.
Observed. No visible emissions were observed during the inspection. Compliance is
indicated.
f. Condition A.7. 15A NCAC 2D .0521 "Control of Visible Emissions". Visible emissions
from wood-fired boiler(ID No. 1) shall not be more than 40 percent opacity.
Observed. This condition doesn't apply anymore. The wood fired boiler has been
removed from the facility and replaced for a gas fired boiler. A letter postmarked March
1, 2016 was received by this office from Hancock &Moore stating these changes. These
changes have been listed on the electronic yellow-sheet.
g. Condition A.B. 15A NCAC 2D .0535 "Notification Requirement". 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. No excess emissions have been reported since the last inspection. Compliance
is indicated.
h. Condition A.9. 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. No fugitive dust emissions were observed during the,inspection. Compliance
is indicated.
i. Condition A.10. 15A NCAC 2D .0611 "Cyclone Requirements" To comply with the
provisions of this permit and ensure that emissions do not exceed the regulatory limits,the
Permittee shall perform an annual inspection of the systems. The results of all inspections
and any variance from the manufacturer's recommendations or from those given in this
permit shall be investigated with corrections made and dates of actions recorded in
logbooks. Records of all maintenance activities shall be recorded in the logbook. The
logbooks shall be kept on-site and made available to DAQ personnel upon request.
Observed.The facility is conducting their annual inspections The last internal inspections
were conducted on April 1, 2019, November 19, 2018, June 2, 2017, and September 6,
2016. Compliance is indicated.
j. Condition A.11. 15A NCAC 2D .0611 "Fabric Filter Requirements" To comply with the
provisions of this permit and ensure that emissions do not exceed the regulatory limits,the
Permittee shall perform an annual internal inspection of the systems. The results of all
inspections and any variance from the manufacturer's recommendations or from those
given in this permit shall be investigated with corrections made and dates of actions
recorded in logbooks. Records of all maintenance activities shall be recorded in the
logbook. The logbooks shall be kept on-site and made available to DAQ personnel upon
request.
t
Hancock&Moore Plant 2
July 09,2019
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Observed.The facility is conducting their annual inspections.The last internal inspections
were conducted on December 30,2018,November 19,2018,June 2,2017,and September
6,2016. Compliance is indicated.
k. Condition A.12. 15A NCAC 2D .0611 "Dynavane Requirements" To comply with the
provisions of this permit and ensure that emissions do not exceed the regulatory limits,the
Permittee shall perform an annual internal inspection of the systems. The results of all
inspections and any variance from the manufacturer's recommendations or from those
given in this permit shall be investigated with corrections made and dates of actions
recorded in logbooks. Records of all maintenance activities shall be recorded in the
logbook. The logbooks shall be kept on-site and made available to DAQ personnel upon
request.
Observed.The facility is conducting their annual inspections.The last internal inspections
were conducted on November 19,2018,June 2,2017,and September 6,2016. Compliance
is indicated.
1. Condition A.13. 15A NCAC 2D .1111 "GENERALLY AVAILABLE CONTROL
TECHNOLOGY"For the wood-fired boiler(ID No. 1),the Permittee shall comply with
all applicable provisions, including the notification,testing, and monitoring requirements.
Observed.This condition doesn't apply anymore.The wood fired boiler has been removed
from the facility and replaced for a gas fired boiler.A letter postmarked March 1,2016 was
received by this office from Hancock&Moore stating these changes.This condition should
be removed from the permit when the boiler is removed from the equipment.These changes
have been listed on the electronic yellow-sheet
8. NSPS/NESHAP Review
There are no generators or fire pumps at the facility,therefore the facility is not subject to NESHAP
Subpart 4Z.There are no gasoline storage tanks at the facility, therefore the facility is not subject
to NESHAP Subpart 6C.The facility has a natural gas fired boiler,but it is not subject to NESHAP
6J.
9. Summary of changes needed to the current permit:
Conditions A.3., A.7., and A.13. should be reviewed as they pertain to the wood fires boiler. The
natural gas fired boiler should be added as an exempt source. These changes were added to the
yellow sheet after the inspection on 07/18/2017.
10. Compliance assistance offered during the inspection:
None.
11. Section 112(r)applicabili1y:
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.
Hancock&Moore Plant 2
July 09,2019
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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.
AFC:Ihe
c: MRO File
https://neconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00034/INSPECT_20190709.doex
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