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HomeMy WebLinkAboutAQ_F_1800377_20191029_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office AIR QUALITY Certainteed Vinyl Operations NC Facility ID 1800377 Inspection Report County/FIPS: Catawba/035 Date: 10/02/2019 Facility Data Permit Data Certainteed Vinyl Operations Permit 06650/R13 2651 Penny Road Issued 10/9/2014 Claremont,NC 28610 Expires 9/30/2022 Lat: 35d 42.4062m Long: 8ld 9.5748m Class/Status Synthetic Minor SIC: 5033/Roofing, Siding and Insulation Permit Status Active NAILS: 42333/Roofing, Siding,and Insulation Material Merchant Wholesalers, Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Brian Lane Rex Todd Brian Lane MACT Part 63: Subpart ZZZZ EH&S Specialist Plant Manager EH&S Specialist (828)459-8944 (828)459-3324 (82'8)459-8944 Compliance Data Comments: _ Inspection Date 10/02/2019 Inspector's Name Sandra Sherer Inspector's Signature• noe Operating Status Operating Compliance Code Compliance-inspection J' Action Code FCE Date of Signature: /bS On-Site Inspection Result Compliance G Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 * HAP 2013 7.07 --- --- 2.54 --- 7.07 318.00 2008 65.05 --- --- 13.79 --- 0.3300 87.99 *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 Certainteed Vinyl Operations October 2, 2019 Page-2— Type Action: X Full Compliance _Partial Compliance _Complaint Other: Evaluation Evaluation/Reinspection Investigation Data Date submitted for initial review 10/10/2019 _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 10/1/2020 Directions: From MRO,travel I-77 north to I-40 west. Take exit 135 (Claremont),turn left onto North Oxford Street and then right onto Main Street(Hwy. 70). Travel approximately one mile and turn left onto Penny Road (at Claremont Industrial Park). The facility is located on the right at 2651 Penny Road. Safety Equipment. Safety glasses,hearing protection,hardhat,safety shoes,and a safety vest are required. Safety Issuesr The facility does a safety talk at the beginning of the tour and asks you to sign a paper. LayTonz Coordinates: The coordinates were last checked in October of 2018 and were accurate. However,the site is currently down. The coordinates in IBEAM are accurate. Email Contacts: IBEAM email contacts were verified with changes required. 1. The purpose of this site visit was to conduct a routine air quality inspection. This facility manufactures vinyl siding. The facility operates 24 hours a day, five days a week. The facility employs approximately 100 full time employees. Mr.Brian Lane,EH&S Specialist, accompanied me during the inspection. 2. Facility Contact Information: During the inspection, I verified the facility contact information in IBEAM. 3. Compliance History: The facility was issued a Notice of Violation on March 25, 2014 for monitoring requirements. 4. Observations of permitted air emission sources and control devices: (------Emission Emission Source Control Control System Source ID Description System ID Descri tion F�p IES-1001 PVC resin vacuum FR-1001 filter receiver(183 railcar unloading system square feet of filter area).; (25,000 pounds per hour maximum capacity) Observed. PVC powder is unloaded from railcars. PVC powder was being unloaded to a silo at the time of the inspection with no visible emissions. Certainteed Vinyl Operations October 2, 2019 Page-3 - :Emission Emission Source Control Control System £� Source ID _ Description � System ID Description ES-1011 PVC storage silo (12,500,BV-1011 bin vent filter(184 pounds per hour square feet of filter area) i maximum capacity) Observed. Once the PVC powder is unloaded from the railcars to the silo, it is transferred from the silos to the process. The process was operating at the time of inspection with no visible emissions. ES-1012 PVC storage silo (12,500;BV-1012 in vent filter(184 pounds per hour square feet of filter area) . maximum capacity) Observed. Once the PVC powder is unloaded from the railcars to the silo, it is transferred from the silos to the process. The process was in operation at the time of inspection with no visible emissions. ES-1015a ,F(2 um carbonate silo ;BV-1015a in vent filter(183 ons per hour fill square feet of filter area) Observed. The calcium carbonate silo is located near the railcar unloading area. Calcium carbonate i"was being loaded into the silo from a truck during the time of the inspection with no visible emissions. ES-1015b calcium carbonate .BV-1.015b _ bin vent filter(226 pneumatic conveyor(2 square feet of filter area) tons per hour maximum ' unloading rate) Observed. The calcium carbonate silo is located near the railcar unloading area. Calcium carbonate 1iwas being conveyed to the process at the time of inspection with no visible emissions. ES-2001 vacuum resin conveying FR-2001 `! _ bagfilter(183 square feet system (19,500 pounds of filter area) t per hour maximum i capacity) Observed. The vacuum resin conveying system is used to transfer PVC resin from the storage silos to the blending operations(heat and cool mixers). The process was observed in operation with no problems noted. j ES-3001 vacuum compound FR-3011,FR-3012, twenty(20)bagfilters conveying system 'FR-3021,FR-3022, (ID Nos. FR-3011,FR- (51,000 pounds per hour FR-3031, FR-3032, 3012,FR-3021,FR- I capacity) consisting of FR-3041,FR-3042, 3022,FR-3031,FR- twenty(20)vacuum ,FR-3051, FR-3052, 3032,FR-3041,FR- conveying lines FR-3062, FR-3072, 3042,FR-3051,FR- FR-3082, FR-3092, 3052,FR-3062, FR- 3072,FR-3082,FR-FR-3102,FR-3061, FR-3071, FR-3081, 3092, and FR-3102,FR- FR-3091, FR-3101 ; 3061,FR-3071,FR- 3081,FR-3091, and FR- Certainteed Vinyl Operations October 2,2019 Page-4— Emission Emission Source Control Control System Source ID Description System ID Description 3 10 1; 183.4 square feet , of filter area, each) installed in parallel. Observed. This system currently is,operating 14 of the vacuum conveying lines,consisting of seven stations with two lines per station. Each line has one bagfilter unit used to transport PVC compound from the storage silos to the vacuum receivers. The exhaust from the system is sent to a blower which then exhausts through a roof vent. Four of the stations (eight vacuum conveying lines)were operating i during the inspection with no visible emissions. F��, 1 cool mixer(24,000 FR-6001 [bagfilter(183.4 square pounds per hour = et of filter area). maximum capacity) - - Observed. Blended compounds from the blending heat mixer are further processed in the cool mixers before being sent to the compound silos that are located inside the building. The process was observed in operation with no problems noted. r ES-6002 ' cool mixer(24,000 ;FR-6002 bagfilter(183.4 square pounds per hour feet of filter area). maximum capacity) Observed. Blended compounds from the blending heat mixer are further processed in the cool mixers before being sent to the compound silos that are located inside the building. The process was observed in operation with no problems noted. ES-6003 blending heat mixer FR-6003 bagfilter(183.4 square (24,000 pounds per hour ' ;feet of filter area). maximum process rate) ' Observed. Blended compounds from the blending heat mixer are further processed in the cool mixers t before being sent to the compound silos that are located inside the building. The process was observed t in operation with no problems noted. ES-7001 glue application line used in construction of N/A N/A cardboard boxes containing vinyl siding r Observed. Water-based glue is stored in plastic totes. There is one(1)hand- spraying line and three (3) automatic spraying lines. The process was observed with no problems noted. ES-8001 barcode labeling system ° including fifteen(15)ink: 'et print heads installed N/A on ten(10) extrusion lines Certainteed Vinyl Operations October 2,2019 Page- 5— Emission Emission Source Control Control System Source ID Description System ID Description Observed. The barcode system operates intermittently and is used to print product numbers and information regarding production on the finished product. Currently only ten ink jet print heads are installed on seven(7)extrusion lines. The process was observed with no problems. ES-8002 PVC grinding operation FR-8002 [lagfilrte (1,530 square (3,000 pounds per hour eet of filter area). i maximum process rate) Observed. Collected waste from the grinding of rejected siding is ground up and recycled. The process. was observed with no problems noted. 5. Observations of insignificant air emission sources and control devices listed on the current permit: -F Source uSource of Source of Title V TAPs? ! pollutants? "IES-5001 -extruder process consisting often(10) n lines (two extruders per line) FYes Yes The extruders are used to make the final product where the PVC compound is sent through a chill roller, preformer roll,water bath and a cutter/stacker. After exiting the extruder process, the vinyl siding is placed into cardboard boxes and sent to the storage area. I-PUMP -diesel-fired fire pump (220 hp) subject to MACT Subpart ZZZZ Yes Yes Observed in operation at the time of inspection with no visible emissions. The hour meter read 276.0 hours at the time of inspection. I-TOWER - cooling tower No Yes The cooling tower was observed with no visible or odorous emissions. 6. Observations of air emission sources and control devices not listed on the current permit: a. None. 7. Compliance with specific permit conditions and limitations: a. Condition A.2. requires the facility to submit the permit renewal application including an emission inventory at least 90 days prior to the expiration date of the Air Permit. Observed. A new air permit was issued on October 9, 2014 due to expire on September 30, 2022. Compliance is indicated for this condition. b. Condition A.3. 15A NCAC 2D .0515 "Particulates from Miscellaneous Industrial Processes"particulate matter emissions shall not exceed allowable emission rates. Certainteed Vinyl Operations October 2,2019 Page-6— Observed. There are no monitoring, recordkeeping or reporting requirements with this stipulation. The allowable emission rates from this facility are not being exceeded. Compliance with this.stipulation was determined during the permit application process. C. Condition AA 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. 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 review of DAQ files and conversation with Mr. Lane, no excess emissions have occurred at the facility in several years. Compliance with this stipulation is indicated. e. Condition A.6. 15A NCAC 2D .0540 "Particulates from Fugitive Dust Control 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 dust complaints received by the MRO concerning the facility and no fugitive dust emissions were observed at the time of this inspection. Compliance with this condition is indicated. f. Condition A.7. 15A NCAC 2D .0958(c) "Work Practices for Sources of Volatile Organic Compounds". Store all VOC-containing material in closed containers when not in use,and clean spills and equipment properly. This condition also requires the facility to comply with work practices for solvents. Observed. VOCs. are only emitted in the bar code labeling system and the glue applications. The glue is contained,in enclosed plastic totes and printing ink and MEK are stored in a locked cabinet. There are no solvents used at the facility. Compliance with this condition is indicated. This condition is no longer relevant,since the facility is in a county that is in attainment with the ozone standard. g. Condition A.8 Federal and State Rules Applicable to Sources Exempted from Air Permitting Requirements - The Permittee shall comply with all applicable provisions including operating restrictions,work practices, monitoring, recordkeeping, and reporting requirements as promulgated in 40 CFR 63, Subpart ZZZZ. Each subject engine shall be operated and maintained in a manner consistent with safety and good air pollution control practices for minimizing emissions.Each subject engine may be operated for 50 hours per calendar year for non-emergency situations. The 50 hours of operation in non-emergency use are counted as part of the 100 hour per calendar year for maintenance and testing. Certainteed Vinyl Operations October 2, 2019 Page-7— The following requirements apply: - change oil and filters every 500 hours of operation or annually, whichever comes first, or utilize an oil analysis program; - inspect air cleaners every 1,000 hours of operation or annually, whichever comes first; - inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary; - and minimize time spent at idle and minimize start-ups to a period needed for appropriate and safe loading not to exceed 30 minutes; - use of diesel fuel with a sulfur content of 15 ppm maximum; and - install non-resettable hour meter. Observed. The facility has a diesel fire pump for emergency purposes which runs on low- sulfur diesel fuel. The fire pump has a non-resettable hour meter which read 276.0 hours at the time of inspection. Since the last inspection on October 2, 2018,the engine has run 27.5 hours. The last two tune-ups were conducted on April 5, 2018 and April 10,2019. h. Condition A.9. LIMITATION TO AVOID 15A NCAC 2Q .501 BAGFILTER REQUIREMENTS. Conduct an annual internal inspection of the filter systems within 12 months from the previous internal inspection. In addition, the Permittee shall perform periodic inspections and maintenance as recommended by the equipment manufacturer and list corrections made and dates of actions in,a logbook. Observed. The facility is currently conducting a minimum of annual internal baghouse inspections. The last two inspection dates are as follows: 1 Emission Emission Source Control Control System Last two inspections Source ID Description System ID Description I ES4001 'PVC resin vacuum FR-1001 filter receiver(183 3/27/18 12/17/18 railcar unloading square feet of filter system(25,000 area) pounds per hour maximum capacity) ES-1011 PVC storage silo BV-1011 bin vent filter(184 7/2/18 5/7/19 (12,500 pounds per; square feet of filter' hour maximum area) capacity) ES-1012 PVC storage silo BV-1012 bin vent filter(184 6/20/18 5/7/19 (12,500 pounds per; square feet of filter hour maximum area) , capacity) Certainteed Vinyl Operations October 2,2019 Page- 8- Emission Emission Source ; Control Control System Last two inspections Source ID Description System ID Description ES-1015a calcium carbonate BV-1015a bin vent filter(183 6/14/18 5/7/19 silo(20 tons per square feet of filter, hour fill rate) area) ES-1015b calcium carbonate BV-1015b ^bin vent filter(226 6/14/18 5/7/19 pneumatic i r square feet of filter conveyor(2 tons area) per hour maximum' unloading rate) ES-2001 vacuum resin FR-2001 bagfilter(183 7/2/18 5/24/19 conveying system ;square feet of filter (19,500 pounds per, area) i hour maximum - capacity) ES-3001 vacuum compound FR-3011,FR- twenty(20) See below conveying system <3012,FR-3021, bagfilters(ID Nos. (51,000 pounds per;FR-3022,FR- FR-3011,FR- hour capacity) 3031,FR-3032, 13012,FR-3021, consisting of ;FR-3041,FR- ;FR-3022,FR- seventeen(17) ,3042,FR-3051, 3031,FR-3032, vacuum conveying,FR-3052,FR- FR-3041,FR- lines 3062,FR-3072, ` 3042,FR-3051, FR-3082,FR- FR-3052,FR- i i 3092,FR-3102, ; 3061,FR-3062, FR-3061,FR- FR-3071,FR- 3071,FR-3081, :3072,FR-3081, FR-3091,FR-3101 FR-3082,FR- 3092,and FR- I 3102,FR-3081, i FR-3091, and FR- 3 10 1; 183.4 square' feet of filter area, each)installed in parallel ------------ Line 1,2 and 4 are not in use. There are two bagfilters per line. Line 3 Units 3031 and 3032 7/1/18 and 6/3/19 Line 4 Units 3041 and 3042 7/23/18 and 6/3/19(the facility keeps this line ready as a standby unit) Line 5 Units 3051 and 3052 6/23/18 and 5/31/19 Line 6 Units 3061 and 3062 6/18/18 and 5/10/19 Line 7 Units 3071 and 3072 6/18/18 and 5/10/19 'Line 8 Units 3081 and 3082 7/7/18 and 5/13/19 Line 9 Units 3091 and 3092 4/5/18 and 5/31/19 i Line10 Units 3101 and 3102 5/13/18 and 6/3/19 ES-6001 cool mixer(24,000 FR-6001 !bagfilter(183.4 '6/4/18 5/24/19 pounds per hour square feet of filter, maximum area) capacity) ES-6002 cool mixer(24,000`FR-6002 bagfilter(183.4 6/4/18 5/24/19 pounds per hour square feet of filter maximum area) capacity) Certainteed Vinyl Operations October 2,2019 Page-9— Emission Emission Source Control Control System Last two inspections i Source ID Description -System ID Description ES-6003 blending heat FR-6003 bagfilter(183.4 8/3/18 5/24/19 mixer(24,000 square feet of filter pounds per hour area) maximum process rate) ES-8002 PVC grinding .FR-8002 bagfilter(1,530 9/30/18 7/9/19 operation(3,000 square feet of filter pounds per hour area) t maximum process ._---- - - - - - .rate) i. Condition A10. 15A NCAC 2Q .0711 "Emission Rates Requiring a Permit." The facility use of MEK is limited to 78 pounds per day or 22.4 pounds per hour. Observed. The facility is keeping MEK usage data. In 2018, the facility used 549 liters of MEK which calculates into 1207.8 lbs/yr or approximately 3.41bs/day. Compliance is indicated for this stipulation. 8. NSPS/NESHAP Review The facility has a diesel fire pump that is subject to NESHAP 4Z. The facility has no boilers or gasoline storage tanks that would be subject to NESHAP 6J or NESHAP 6C, respectively. 9. Summary of changes needed to the current permit: Remove Condition A.7. 15A NCAC 2D .0958(c) "Work Practices for Sources of Volatile Organic Compounds" from permit since facility is in a county that is in attainment with the ozone standard. This change was added to the facility's yellowsheet. 10. Compliance assistance offered duringthe inspection: None. 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. SLS:lhe c: MRO File https://neconnect.sharepoint.com/sites/DAQ-MRO/Counties/CATAWBA/00377/INSPECT_20191002.doex