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HomeMy WebLinkAboutAQ_F_0200083_20190829_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office AIR QUALITY Hickory Springs Hiddenite NC Facility ID 0200083 Inspection Report County/FIPS: Alexander/003 Date: 08/29/2019 Facility Data Permit Data Hickory Springs Hiddenite Permit 08502/R04 161 Sharpe Lane Issued 4/13/2016 Hiddenite,NC 28636 Expires 3/31/2024 Lat: 35d 54.0973m Long: 8ld 5.3202m Class/Status Small SIC: 3086/Plastics Foam Products Permit Status Active NAILS: 32614/Polystyrene Foam Product Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Nancy Duffey James Bush Steve Hannah Du MACT Part 63: Subpart 60 Plant Manager President Corporate EHS (828)632-9733 (828)328-2201 Manager 828 328-2213 Compliance Data Comments: Inspection Date 08/29/2019 Inspector's Name Alejandra Cruz Inspector's Signature: Operating Status Operating Compliance Code Compliance-inspection �� J Action Code FCE Date of Signature: On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2015 --= --- --- 11.38 2010 --- --- --- 7.44 * --- Highest HAP Emitted inpounds) Five Year Violation History:None Date Letter Tyne Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested Hickory Springs August 29,2019 Page-2— Type Action: X Full Compliance _Partial Compliance _Complaint Other: Evaluation Evaluation/Reinspection Investigation Data Date submitted for initial review 8/29/2019 —1BEAM 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 08/01/2021 Directions: Traveling I-77 north to Statesville,take I-40 west to exit 148.Turn right onto highway 64/90 west.Travel approximately .25 miles and turn right onto highway 90 west.After 13 miles,turn right onto sulfur springs road.Travel approximately 200 feet, cross the railroad tracks,and then turn right onto Sharpe street.The facility is located on the left. Safety Equipment: Safety glasses 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 locked. Email Contacts: Email contacts found in IBEAM were verified.The technical contact,Mr. Steve Hannah will send an email with the information of the current authorized contact since the previous president retired. 1. The purpose of this site visit was to conduct a routine air quality inspection.This facility cuts and glues pieces of foam into cushions, etc., for the furniture and medical industry.The facility is currently operating two eight-hour shifts, five days per week with approximately 62 employees. Ms. Sandra Sherer of the MRO DAQ coinspected the facility with me. Ms. Candy Duffey, Plant manager, accompanied us during this inspection. 2. Facility Contact Information: During the inspection I verified the facility contact information in IBEAM. The invoice contact data will be change to Ms. Candy Duffey, Plant Manager. Ms. Sandy Sherer has the information and will be changing the invoice contact data. The authorized contact data changed; Mr. Hannah will send me the information of the new authorized 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. Hickory Springs August 29, 2019 Page -3 — 4. Observations of permitted air emission sources and control devices: Emission Emission Source Control j Control System I E Source ID Description System ID Description- - - -- ----- - -- ES-F-01 (NESHAP) { flexible polyurethane foam gluing operation N/A j N/A Observed.The operation consists of two parts: the first is a spray conveyor,used to glue together large ! Isheets of foam, guided by an electronic eye and a gang sprayer system;the second is a group of eight gluing stations with a low pressure,high volume spray gun at each station.The facility now has nine spray stations.Each station is covered with brown paper, and it is changed every week. All spray stations were in operation. The conveyor was not in operation during the inspection. - 5. Observations of insignificant air emission sources and control devices listed on the current permit: a. None noted. 6. Observations of air emission sources and control devices not listed on the current permit: a. None noted. 7. Compliance with specific permit conditions and limitations: a. Condition A.2. 15A NCAC 2D .0202 The Permittee, at least 90 days prior to the expiration date of this permit, shall request permit renewal by letter. Observed.The current permit does not expire until 03/31/2024. Compliance is indicated. b. Condition A.3. 15A NCAC 2D .0521 "Control of Visible Emissions," visible emissions from the emission sources, manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged. Observed. No visible emissions were observed during the inspection.Compliance is indicated. C. Condition A.4. 15A NCAC 2D .0535,the 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. Observed. No excess emissions have been reported since the last inspection. Compliance is indicated. d. Condition A.5. 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. Hickory Springs August 29, 2019 Page -4— e. Condition A.6. 15A NCAC 2D .0958(c), for all sources at facilities that use volatile organic compounds (VOC) as solvents, carriers, material processing media, or industrial chemical reactants, or in similar uses that mix, blend, or manufacture volatile organic compounds, or emit volatile organic compounds as a product of chemical reactions; the Permittee shall adhere to the required work practices. Observed. This condition no longer applies to counties designates as attainment for ozone. These changes have been listed on the electronic yellow-sheet. f. Condition A.7. The Permittee shall comply with all applicable provisions of 40 CFR 63, Subpart 000000 "National Emission Standards for Hazardous Air Pollutants for Flexible Polyurethane Foam Production and Fabrication Area Sources", including Subpart A "General Provisions." Standards,and Compliance a) For foam fabrication operations with loop slitters, the Permitee shall retain on site a statement signed and dated by a responsible official stating that the facility does not use any adhesive containing methylene chloride in a flexible polyurethane foam fabrication process. b) Permittee shall not use any adhesive containing methylene chloride in a flexible polyurethane foam fabrication process. Recordkeeping Requirements a) The Permittee shall demonstrate compliance using adhesive usage records, Material Safety Data Sheets or engineering calculations. Observed. The facility uses spray guns to add the glue to the foam. No loop slitters are used in the process.According to the MSDS the adhesive is a foam solvent-based adhesive from Worthen Industries,Inc.The MSDS also indicated that this adhesive does not contain methylene chloride. Compliance for this condition 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. Observed. No odors were detected during the inspection. Compliance is indicated. 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 boilers at the facility, therefore the facility is not subject to NESHAP Subpart 6J. There are no gasoline storage tanks at the facility, therefore the facility is not subject to NESHAP Subpart 6C. Hickory Springs August 29, 2019 Page-5— 9. Summary of changes needed to the current permit: The 2D .0958 condition can be removes because the rule no longer applies to counties designates as attainment for ozone. The electronic yellowsheet for permit changes needed has been completed and placed in the facility's electronic file. 10. Compliance assistance offered during the inspection: None. 11. Section 112(r) gpplicability: 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. AFC:lhe c: MRO File https://neconnect.sharepoint.com/sites/DAQ-MRO/CountiesiALEXANDER/00083/INSPECT 20190829.docx