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HomeMy WebLinkAboutAQ_F_1900039_20190624_CMPL_InspRpt (4) V11p) NORTH CAROLINA DIVISION OF Raleigh Regional Office AIR QUALITY Southern Veneer Specialty Products,LLC- Moncure Inspection Report NC Facility ID 1900039 Date: 06/24/2019 County/FIPS: Chatham/037 Facility Data Permit Data Southern Veneer Specialty Products,LLC-Moncure Permit 03424/T28 306 Corinth Road Issued 3/19/2019 Moncure,NC 27559 Expires 12/31/2019 Lat: 35d 36.5760m Long: 79d 2.9560m Class/Status Title V SIC: 2436/Softwood Veneer And Plywood Permit Status Active NAICS: 321212/Softwood Veneer and Plywood Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP/Title V Tom Reams Ora Kendall Adams Tom Reams MACT Part 63: Subpart ZZZZ EHS Manager Managing Member EHS Manager NSPS: Subpart Dc,Subpart IIII (919)642-7011 (229)424-0294 (919)642-7011 Compliance Data Comments: In Violation-permit not available(General Condition 3.13);no recording and maintaining records of monthly fuel burned(ES01-B)per 2D Inspection Date 06/24/2019 .0524 NSPS Subpart Dc; missing records of differential pressure drop per 2D Inspector's Name Matthew Mahler .0614 CAM; and not maintaining and recording monthly HAPs emissions per Operating Status Operating 2D.0317 Avoidance of 1 SA NCAC 2D.1111. Compliance Code Compliance-inspection Action Code FCE Inspector's Signature: —71» -;W aZ, — On-Site Inspection Result Violation Date of Signature: r612—/ ! ZC'l / Total Actual emissions in TONSIYEAR: TSP S02 NOX VOC CO PM10 *HAP 2017 54.85 0.6900 43.01 70.06 31.03 54.64 12011.69 2016 59.06 0.6500 40.82 64.64 33.94 58.81 13445.44 2015 60.75 0.7100 44.84 63.28 26.61 60.73 14181.18 *Highest HAP Emitted(in pounds) Five Year Violation History: Date Letter Tvve Rule Violated Violation Resolution Date 11/20/2018 NOV Permit Late Report(excluding ACC) 12/19/2018 11/20/2018 NOV Part 60-NSPS Subpart IIII Stationary Compression 12/19/2018 Ignition Internal Combustion Engines 08/10/2015 NOV 2D.2600 Source Testing 07/30/2016 Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested (1)DIRECTIONS TO SITE: Southern Veneer Specialty Products,LLC-Moncure(Southern Veneer)is located at 306 Corinth Road(SR-1916)in Moncure,NC, Chatham County. From Raleigh,take US-1 South to Old US-1 (SR-1011)and turn south(right). Travel approximately 3.5 miles and turn east(left)on Corinth Road(SR-1916). The plant entrance is on the right,just past the railroad tracks. (II)FACILITY DESCRIPTION:The Moncure facility was recently purchased by Southern Veneer. This plywood plant manufactures plywood from hardwood(poplar)veneer and pine veneer. The plywood ranges from 3 to 9 plies, and from"/32-inch to 1 V4-inch thick. The facility receives trees,cuts them to length(10 feet),and debarks the wood. The bark is hammer milled,transferred to silos,and used as wood fuel. The logs are heated in steam vats for about 24 hours to soften. The more the logs are heated,the less glue is required. The logs are then sent to a spindle lathe. The lathe cuts continuous,thin sheets of veneer from each log. The 22-inch core of the log is sold as battens(for packaging). Wood chips are further processed for wood fuel or for sale to other wood products facilities. Veneers are cut into 4 feet x 8 feet pieces and then dried in dryers, glue is applied,pieces are aligned in the composer and lay-up lines, and then are pressed in the plywood presses. The plywood is then sawed to specifications and stacked for sale. Wood waste is used as fuel. Most of the plywood is used to construct upholstered furniture. The facility produces softwood plywood,hardwood plywood, and composite plywood(both softwood and hardwood). The actual production of the plywood typically occurs six days/week. The dryers typically operate five days per week,24 hours per day. Presently,there are 100 employees at the facility. Be prepared to use standard safety items at this facility. (III) INSPECTION SUMMARY: On June 24, 2019,I(Matt Mahler) arrived on the site to perform a compliance inspection. The Facility Contact,Ms.Caitlyn Payne,was no longer with Southern Veneer. The new Facility Contact, Mr.Tom Reams,met me at the guard shack at the entrance to the facility. We proceeded to Mr.Reams' office where we reviewed the permit conditions and required records. I provided a copy of the permit for review as Mr. Reams slid not have a copy available. Mr. Reams indicated that much of the air quality environmental records were removed from site when Boise Cascade sold the company to Southern Veneer. Records are maintained at the utility building. The records appeared to be well maintained and complete, except for the following: • the facility was unable to produce a copy of their air permit during the inspection(General Condition 3.13); • the facility was not recording and maintaining records of the amount of wood fuel burned during each month in the Boiler(ES01-B)as required by 2D .0524 NSPS Subpart Dc; • the facility was not recording the differential pressure drop across the multicyclone(CD02)on two days of operation in 2019 as required by 2D .0614 CAM; and • the facility was not maintaining and recording monthly HAPs emissions as required by 2D.0317 Avoidance of 1 SA NCAC 2D.I I 11 Limitation To Avoid Being Major For Hazardous Air Pollutants. It is recommended that a Notice of Violation(NOV)be issued to the facility for these monitoring and recordkeeping Age-Mgd to tour the,facili�y. Most of the equiprn@PA was operating at the facility. Comments about observations made during the inspection are provided below for each of the emission sources and specific air quality regulations listed in the facility's current air permit. Overall,the facility appeared to be managed well. Note: The new electronic yellow sheet stored on the NCDAQ AQLAN was updated to show that the emission source description of ES-23 should be changed from generator to water pump engine in the next permit revision. (IV)PERMITTED EMISSION SOURCES: On the day of the inspection,the facility was operating under Air Permit No. 3424T28. This permit became effective on March 19, 2019 and expires on December 31, 2019. This permit includes the following emission sources and control devices: (a) one multicyclone (ID No. CD-02) installed on a blend chamber controlled fluidized bed wood burner(ID No. ES-01-A)and boiler ES-01-B); There was some exhaust coming from the wood burner dump stack on the day of the inspection. According to the staff,the boiler dump stack exhausts excess gases (and heat)when not required by the veneer dryers. The flow diagrams indicate that the heated gases from the burner are directed either towards the boiler(to produce facility steam) or to the dryers to process the veneer. In another diagram provided by the facility, it appears that the gases headed to the dump stack and the gases directed towards the dryers are processed by a multicyclone. Some of the gases from the boiler and the dryers are recirculated back to the wood burner. The balance of the gases is emitted from the six stacks(3 for each dryer)or escape as fugitive emissions. The boiler has a maximum rating of 150 psi and a maximum rated heat capacity of 29.79 mmBtu/hr. The wood burner was operating on the day of the inspection. On the day of the inspection,the pressure drop across the multicyclone was 0.17 inches since the dryer was down. (b) two direct wood-fired veneer dryers (ID Nos. ES-09 and ES-10); Both the dryers were operating on the day of the inspection. These two dryers directly utilize the exhaust gases from the fluidized bed wood burner. The visible emissions of the plume from this dryer was 0%opacity. (c) one cyclone (CD-03-WWTC)and one bagfilter(ID No. CD06) installed on: • two string machines including saws (ID Nos. ES03-SMS-1,2); • one core saw(green or dry veneer) (ID No. ES03-CS); • one strip saw(ID No. ES03-SS); • one core composer saw(ID No. ES03-CC); • one panel sawing system (ID No. ES03-PSS); • one plywood hog(ID No. ES16);and • green wood sizing operations (ID No. ES17); • tongue and groove saw(plywood finishing)(ID No. ES22) The core saw and the panel sawing system had operated early during the day,but was not operating during the onsite tour. The core composer with saw was operating. All other sources were not operating during the onsite tour. Mr.Reams indicated that the two string machines have not operated since 2018. The bagfilter(CD06)was operating at the time of the physical tour and no visible emissions were evident.The magnehelic gauge reading was 0.5 inches of water; Mr.Reams indicated that a good operating range is from 0-3 inches of water. Of note,the strip saw is referred to as the wedge saw and the plywood waste hog is referred to as the dry hog. (d) one cyclone (ID No. CD18) installed on rechip blow hog(ES14) along with one woodwaste transfer cyclone (CD-03-WJfTQ16ne bagfilter(ID No. CD06); This equipment was operating at the time of the inspection with no visible emissions evident. (e)one bagfilter(ID No. CD05)installed on a wood sander(ID No.ES04)along with one woodwaste transfer cyclone (CD-03-W97C)/one bagfilter(ID No. CD06); This equipment was operating at the time of the inspection with no visible emissions evident. Mr.Reams indicated that the wood sander,ES04, operates infrequently. (f)one cartridge filter(ID No. CD21) installed on a dry wood residual storage silo (ID No. ES12); The silo has been repaired from an earlier fire. Presently the silo appears to be in adequate condition. (g) one vat operation (ID No. ES20); There were vats in operation during the physical tour. Two are collocated in one structure. The other five vats are adjacent to each other forming another structure. (h) one end sealer spray booth (ID No. ES21); The equipment was not-in-service. Mr. Reams believes that ES21 was taken out of service in the 2015-2016 timeframe. (i) one glue mixing operation (ID No.ES-13-GMO); The equipment appeared to be sound and well maintained. The equipment was operating during the tour. 6) one curtain coater(ID No.ES-13-CC); The equipment appeared to be sound and well maintained. The equipment was not operating during the tour as the personnel were on break. (k) one paper overlay operations(ID N6.ES-13-PO); The equipment appeared to be sound and well maintained. The equipment was not operating during the tour as the personnel were on break. (l) one plywood spreader(ID No.ES-13-PS); The equipment has been removed from the facility. Mr. Reams said that the equipment was possibly removed from site in the 2015-2016 timeframe. (m) one 25 panel hotpress(ID No.ES-13-25HP); and This equipment was not-in-service. (n) one 40 panel hot press (ID No.ES-13-40HP); The equipment appeared to be sound and well maintained. The equipment was operating during the tour. (V)APPLICABLE AIR QUALITY REGULATIONS:As is the case with all Title V permits,Air Permit No. 03424T28 lists all of the air quality regulations that apply to each of the permitted emission sources. To avoid redundancy in this report,the applicable air quality regulations are discussed individually, and all of the permitted emission sources that are subject to a specific regulation are noted. (1) 15A NCAC 2D.0512:PARTICULATES FROM MISCELLANEO US WOOD PRODUCTS FINISHING PLANTS— The following emission sources are subject to 2D.0512:All woodworking operations and Edge Sealing Spray Booth (ID Nos. ES-03-SMS 1,2,ES-03-CS,ES-03-SS, ES-03-CC,ES-03-PSS,ES-04,ES-12, ES-14, ES-16,ES-17, ES-21, & ES22). IN COMPLIANCE-In accordance with 15A NCAC 2D .0512,the permittee shall not cause, allow,or permit particulate matter caused by the working, sanding, or finishing of wood to be discharged from any stack,vent, or building into the atmosphere without providing, as a minimum for its collection, adequate duct work and properly designed collectors. All duct work and control devices installed on woodworking equipment were observed during the inspection in good physical condition. No particulate emission testing is required for any of these sources by the facility's air permit. The permit does require the facility to conduct monthly and annual inspections of the cyclones and bagfilters installed on the wood working equipment,record the results of any inspection and maintenance activities in a logbook, and submit a semiannual deviation report to DAQ. Also,the permit requires that weekly visible emission monitoring be performed on the other wood-finishing units. Upon request,the facility provided records of the weekly,monthly and annual inspection activities. Additionally,the facility has submitted the required semiannual reports on time summarizing the facility's monitoring and record keeping activities. (2) 15A NCAC 2D.0515:PARTICULATES FR OM MISCELLANEO US INDUSTRIAL PROCESSES- The following emission sources are subject to 2D.0515: The fluidized bed wood burner(ID No. ES 01-A), the associated boiler(ID No. ES-01-B), and two associated direct wood-fired veneer dryers(ID Nos. ES-09, ES-10). IN COMPLIANCE-The particulate emission limit for the wood burner and associated veneer dryers is determined by the processed material in the system including the wood fuel and the dried veneer. To demonstrate compliance with this requirement,the previous air permit(T24—the first revision in the renewal cycle)required that a performance test(for particulate matter) and the test results be submitted within 180 days of the permit issuance. This would make for a July 20,2015 due date. Actually,the required performance test was not completed until June 30, 2016 and the report was not submitted until July 29, 2016. A Notice of Violation was issued on August 10, 2015 due to the lateness of the required testing project. When the test results were finally submitted and reviewed,the Stationary Source Compliance Branch(SSCB)indicated that the test results(12.1 lb./hr.)met the particulate limit(17 lb./hr.). One of the reasons for the delay of the testing project was the fact that the facility was advised to change to a different type of air jet in the wood burner. These new jets apparently caused combustion issues. The facility eventually removed these air jets and replaced them with the original type. The most recent annual internal inspection of CD02 was conducted on December 26, 2018. (3) 15A NCAC 2D.0516:SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES- The following emission sources are subject to 2D.0516.- The fluidized bed wood burner(ID No. ES-01-A). IN COMPLIANCE-The sulfur dioxide emission limit for each of these sources is 2.3 pounds per million Btu heat input. Since the facility burns exclusively wood waste and diesel fuel in its combustion equipment,the 15A NCAC 2D .0516 sulfur dioxide emissions standard should be achieved during normal operating conditions. Sulfur dioxide emissions testing/monitoring/record keeping/reporting is not required for these sources by the facility's air permit. (4) 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-All of the permitted emission sources are subject to 2D.0521. IN COMPLIANCE-The visible emission limit for all plant emission sources is 20%opacity. During the inspection, visible emissions related to the dryer operation were observed as 0%opacity,which is an improvement from the opacity noted during a prior inspection report. The following excerpt was taken from the 2017 inspection report. "On a previous site visit(October 23, 2013) while travelling to Arauco (across the road) to perform a stack test observation. I(Steve Carr) observed and photographed stack/rooftop visible emissions that appeared to be excessive. On the following week,I sent an email with attached photographs to Mr. Van Gelder. Mr. Van Gelder indicated that the new owner(Southern Veneer)was motivated to correct the visible emissions problem. On January 6, 2014,Mr. Van Gelder sent an email that described some equipment modifications that the facility is considering that might help decrease visible emissions. Some of the modifications listed in the email include the replacement of M62 baffles, electronic control upgrades for the boiler, and installing variable frequency drives. These changes included new ductwork to capture fugitive emissions and were noted on the last inspection (January 14, 2015). The ductwork modifications were discussed during the last inspection (January 29, 2016) and it appears that they were not effective in decreasing figitive emissions. During this inspection (March 9, 2017), the visible emissions from the dryer stacks did not appear to be remarkable." The permit does require the facility to perform periodic visible emissions observations on the boiler and woodworking operations,record the results of the observations in a logbook, and submit a summary report of the observations on a semiannual basis. Upon request,the facility provided records of the required visible emission observations. Additionally,the facility has submitted the required semiannual reports on time summarizing the facility's monitoring and record keeping activities. (5) 1 SA NCAC 2D.0524:NEW SOURCE PERFORMANCE STANDARDS(40 CFR 60, Subpart Dc)- The following emission source is subject to NSPS Subpart Dc:Boiler(ID No. ES-01-B). IN VIOLATION-To comply with the requirements of 40 CFR 60,Subpart Dc-Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units,the facility must record and maintain records of the amount of wood fuel burned during each month. Mr. Reams stated that he was not recording fuel use records and he was unable to present these records during the inspection. Mr.Reams indicated that much of the air quality environmental records were removed from site when Boise Cascade sold the company to Southern Veneer. Mr. Reams was not aware of this permit requirement. (6) 1 SA NCAC 2D.0614: COMPLIANCE ASSURANCE MONITORING- The following emission sources are subject to 2D.0614: The fluidized bed wood burner(ID No. ES-01-A). and woodworking operations (ID Nos. ES-03-SMS-1,2, ES-03-CS, ES-03-SS, ES-03-CC, ES-03-PSS, ES-04, ES-12, ES-14, ES-16, ES-17, &ES-22). IN VIOLATION-To comply with 15A NCAC 2D .0614,the pemuttee is required to record the differential pressure across the multicyclone(CD02)to ensure that the pressure drops fall between 4"and 13". This pressure requirement was recently added in the T25 version of the facility air permit. The facility is monitoring the pressure drops across the multicyclone as required and most differential pressure records were available for review. The fluidized bed wood burner was in operation on April 30,2019 and May 6,2019;however,the recordkeeping provided by Mr.Reams did not have any differential pressure recorded on those two days as required. The facility is required to provide a summary of excursions in their semi-annual reports. The 2°d half 2018 semiannual reported indicated excursions triggered a QIP during that reporting period. For the woodworking operation,a Method 22 type observation is required to be performed daily on each bagfilter outlet. The records I reviewed during the inspection together with the records emailed to me after the inspection appeared to indicate compliance to this daily opacity observation requirement. (7) 1 SA NCAC 2D .I100 and 2Q.0711: TOXIC AIR POLLUTANT REQUIREMENTS-All of the permitted emission sources are subject to 2D.1100 and 2Q.0711. IN COMPLIANCE-Through the results of past air modelung,the c��ussior�rates of air pollutants were established. From a review of the 2016 Emission Inventory,it appears that the emission rates for the pollutants of concern were below the listed thresholds in the air permit. (8) I5A NCAC 2Q.0317:LIMITATION TO AVOID BEING A MAJOR FOR HAZARDOUS AIR POLL UTANTS-A11 of the permitted emission sources are subject to 2Q.0317. IN VIOLATION-To avoid being a major source for hazardous air pollutants(HAPs)under 40 CFR Part 63, the facility must limit facility-wide emissions to 10 tons per year of any listed HAP and 25 tons per year for all HAPs combined. The former owner of this facility(Boise Cascade)performed an internal audit in April,2014. During the audit, it was discovered that the hardwood emission factor that was being used for methanol emissions from the presses was potentially lower than it should be. The methanol emission factor that was being used had been taken from EPA AP-42 and was based on hardwood plywood being processed with a urea formaldehyde-based adhesive. In contrast,this facility processes its hardwood plywood with a phenol formaldehyde-based adhesive which potentially might emit higher methanol emissions. The stack test performed on December 10, 2014 indicated that the methanol emission factor for their hardwood plywood should be 0.116 lb./MM sq.ft.instead of the AP-42 factor(0.0321b./MM sq. ft.). This same stack test indicated that the methanol emission factor for their softwood plywood should be 0.106 lb./MM sq. ft.instead of the AP-42 factor(0.14 lb./MM sq. ft.). The impact of changing these emission factors increased the facility-wide 12-month rolling methanol emissions. One of the highest 12-month rolling totals of methanol for CY 2018 was 7.2 tons in November 2018. One of the lowest 12-month rolling totals of methanol for CY 2018 was 6.3 tons in January 2018. The facility must also maintain monthly HAPs emissions records. Mr.Reams indicated that the facility has not been maintaining or recording HAPs emissions. Mr.Reams indicated that much of the air quality environmental records were removed from site when Boise Cascade sold the company to Southern Veneer. Mr.Reams was not aware of this permit requirement. (9) 15A NCAC 2D.1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS-All of the permitted emission sources are subject to 2D.1806. IN COMPLIANCE—To comply with 15A NCAC 2D .1806, 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. No objectionable odors were detected during the compliance inspection. No odorous emissions testing/monitoring/record keeping/reporting is required by the facility's air permit. There are no odor complaints recorded in the Complaint Module(IBEAM). (VI) OTHER REGULATORY REQUIREMENTS: (1) 15A NCAC 2D.0524:NEW SO URCE PERFORMANCE STANDARDS(40 CFR 60, Subpart IIII)- The following emission sources are subject to NSPS Subpart IIII.• The 250 horsepower(maximum) diesel fire pump (IES-23). IN COMPLIANCE—To meet the requirements of this regulation,the generator engine must meet a particulate matter, carbon monoxide, and a combined NMHC+NOx limit. Also,the facility has to maintain the engine according to the manufacturer's recommendation. The facility was able to provide a Certificate of Conformity for this engine(IES-23). This is the primary backup pump, which automatically turns on when the water pressure drops below a set point through the facility(100 psi). According to their staff,there are incidences where the pumps are needed for fire-related issues. The hour meter on the generator indicated 1112.3 hours on the day of the inspection and 979.9 hours during the September 2018 inspection. The facility had received an NOD dated May 31,2018 at a time when the fire pump engine was classified for emergency use. This NOD was for exceeding the 50-hour limit for non-emergency use for IES-23 according to the Subpart IIII requirements of the prior permit version T27. Since then,the facility has installed an electric jockey pump engine to supply process water as a backup pump. The facility modified their permit(current T28)to reclassify IES-23 as a non-emergency engine. The facility provided records of maintenance which showed that the most recent engine maintenance was conducted on November 5, 2018. The facility conducted regularly scheduled maintenance on a 6-month,yearly and two-year maintenance schedule. (2) 15A NCAC 2D.1111:A1WATUM A CHIE VABLE CONTROL TECHNOLOGY(40 CFR 63, Subpart ZZZZ)- The following emission sources are subject to 2D.I 111: The 190-horsepower diesel fire pump (IES-23) and the 250 horsepower diesel fire pump (IES-19). IN COMPLIANCE—Since IES-23 was manufactured after 2006, satisfying the requirements of 40 CFR 60, Subpart IIII, satisfies the requirement of this regulation(see above). Past records indicate that IES-19 is complying with the maintenance requirements of this regulations. According to the hourly records(as noted above)the non-emergency usage of IES-19 appears to be less than the 50-hour limit. This unit had 1520 hours on January 5, 2014, 1588 hours during the 2017 inspection, 1631.4 hours on September 6,2018 and 1658.2 hours on June 24,2019. (VII)EXEMPT EMISSION SOURCES:The facility currently has several emission sources listed on the Insignificant Activities List attached to the current air permit. Some of these sources were observed during the inspection. No concerns were noted with regard to their operation or permit exemption status. In addition,Mr.Reams indicated that the facility operates 1500 kW Generac Model No. 62480 propane-fired emergency generator to power the facility's servers during power outages. The unit was purchased around the 2013-2014 timeframe. It was serviced in 2017 and had an hours-meter reading of 54.5 hours on August 28, 2018. The unit's engine serial number is E8954800. (VIH)ENFORCEMENT HISTORY: The former Moncure Plywood has been issued two Notices of Violation/Notice of Recommendation for Enforcement(NOWNRE),five Notices of Violation(NOVs), and two Notices of Deficiency(NOD)according to DAQ records. In 2018,the facility had submitted a modified permit application to NCDAQ to reclassify IES-23 as a non-emergency engine under NSPS MI. Prior to submitting this application,the facility exceeded the 50-hour limit and the 100-hour limit(sum of non-emergency,readiness testing and maintenance use)in 2018. A NOV was issued to the facility on November 20, 2018 for the 2018 exceedances. On May 31, 2018,the facility was issued an NOD per the requirements of NSPS MI for exceeding the 50-hour limit for non-emergency use for IES-23. On August 10, 2015,a NOV was issued to the facility for not performing a stack test within the required time frame. On June 5,2014,a NOD was issued to the facility for not maintaining records for the required five years. On February 8, 2011,an NOV was issued due to a late stack test report. On February 26, 2010,a NOV/NRE was issued for missed visible emissions observations and inspections. The company was assessed $4666 in civil penalties for these violations. On November 1, 2007,the company was issued a NOV for not maintaining a cyclone unit effectively so to prevent excess particulate emissions. Also this same NOV noted that records tracking the BTU heat input to the steam generating unit were not complete. On June 7,2007,the company was issued an NOV/NRE for various Title V monitoring and record keeping violations. The company was assessed $2913 in civil penalties for these violations. Prior to that,the company was issued an NOV on June 14, 2006 for previous Title V monitoring and record keeping violations. No civil penalties were assessed against the company in this case. (IX) STACK TEST REVIEW: As indicated above in Section V. (2),Air Permit 03424/T24 requires that a particulate test be performed on the fluidized bed wood burner(ESO1-A)and the associated dryers(ES09,ES 10) within 180 days from the permit issuance date. This permit being issued on January 21,2015 would require that the test results be submitted by July 20,2015. The required performance test was finally completed on June 30, 2016 with the test results submitted on July 29, 2016. The results were reviewed by SSCB with the conclusion that compliance to the particulate standard was indicated. A performance test to determine more accurate methanol emission factors for the presses was per�� ed on December l O,2014. Another perfon. ance test was performed on November 20, 2012. The purpose of the testing was to demonstrate compliance with 40 CFR 63 Subpart JJJJJJ(6J)by measuring the effectiveness of a tune up by monitoring carbon monoxide(CO) concentrations. The test results were accepted by SSCB. (X)EMISSION INVENTORY REVIEW: The following review was provided by the 2017 Emission Inventory DAQ internal comments in IBEAM.Acrolein and benzene emission increases were driven by changes in hardwood/softwood production ratio for veneer dryers and heat source(wood burner)(Emission Group 24). MEK emission decrease driven by reduction in throughput for OS 30 (Veneer dryers and heat source(wood burner), hardwood)and OS 28 (glue mixing, application and hot presses operations, softwood). The methanol emission decrease was driven by reduction in throughput for multiple emission sources,including OS28 & 10(glue mixing), OS 30 (Veneer dryers and heat source(wood burner),hardwood), and OS12(Wood sander). The phenol emission decrease was driven by reduction in throughput for OS28 & 10 (glue mixing), and OS 30 (Veneer dryers and heat source(wood burner),hardwood). The propionaldehyde emission decrease was driven by reduction in throughput for OS 27& 30 (Veneer dryers and heat source wood burner). (XI)CONCLUSIONS/RECOMMENDATIONS:Based on observations made during the June 24,2019 inspection, Southern Veneer was in violation with the requirements of their Title V permit. It is recommended that a Notice of Violation(NOV)be issued to the facility for not having available a copy of the facility's air permit during the inspection(General Condition 3.B); for not recording and maintaining records of the amount of wood fuel burned during each month in the Boiler(ESO 1-B)as required by 2D .0524 NSPS Subpart Dc,for not recording the differential pressure drop across the multicyclone(CD02)on two days of operation in 2019 as required by 2D.0614 CAM;and for not maintaining and recording monthly IIAPs emissions as required by 2D.0317 Avoidance of 1 SA NCAC 2D.1111 Limitation To Avoid Being Major For Hazardous Air Pollutants. It is also recommended that the facility be re-inspected in one year.