AQ_F_0200039_20190221_CMPL_CAV-Rpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Daniels Woodcarving Company,Inc.
NC Facility ID 0200039
Inspection Report / County/FIPS:Alexander/003
Date: 02/21/2019
Facility Data Permit Data
Daniels Woodcarving Company,Inc. Permit n/a
2325 Highway 90 East Issued n/a
Taylorsville,NC 28681 Expires n/a
Lat: 35d 54.9840m Long: 81d 8.2410m Class/Status Permit Exempt
SIC: 2511 /Wood Household Furniture Permit Status Inactive
NAICS: 337122/Nonupholstered Wood Household Furniture Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
David Daniels David Daniels David Daniels
MACT Part 63: Subpart 6J
CEO CEO CEO
[phone] [phone] [phone]
Compliance Data /
Comments: ✓/
Inspection Date 02/21/2019
Inspector's Name Donna Cook
Inspector's Signature: o a Coo Operating Status Operating
Compliance Code Compliance-inspection
/ Action Code FCE
Date of Signature: J// On-Site Inspection Result Compliance
Total Actual emissions in TONSIYEAR:
TSP S02 NOX VOC CO PM10 *HAP
2012 0.0300 --- 0.0200 --- 0.0300 0.0200 1.59
2007 0.0300 --- 0.0100 --- 0.0100 0.0300 0.8800
*Hi hest 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

Daniels Woodcarving Company, Inc.
February 21,2019
Page 2
Type Action: _Full Compliance _Partial Compliance _Complaint X Other: Compliance Assurance Visit
Evaluation Evaluation/Reinspection Investigation fQAYA
Data Tracking: X Date submitted for initial review 03/02/2019 v _IBEAM WARNING/OB,NOD,NOV,NRE
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 02/01/2021
Directions: From Mooresville Regional Office to Taylorsville,travel via Statesville Avenue;North
Broad Street and the name changes to Statesville Highway(Highway 115 North)and then to Charlotte
Highway(Highway 21 North and Highway 115 North);Interstate 77 North;Exit 51 (Hickory/Winston-
Salem)-Interstate 40 West toward Asheville; off Interstate 40 West take Exit 148-W. Statesville/
Taylorsville US Hwy. 64/NC 90;turn right off exit ramp onto Taylorsville Road US Hwy. 64; 14 '/2
miles turn right on Adams Pond Lane. 0.3 mile turn right on Hwy. 90 East; and immediately on the left is
this facility. The street address of this company is 2325 Highway 90 East.
Safety Equipment: This company requires that safety glasses and hearing protection be worn by the
inspector at this facility.
Safety Issues: No safety issues were observed by me during the inspection.
Lat/Lone Coordinates: The facility's coordinates on "Maps of DAQ Regulated Facilities" are not
accessible on the DAQ web site. The latitude and longitude coordinates of this facility in IBEAM are
accurate and locked.
Email Contacts: The email addresses for the facility, authorized and technical contacts were verified by
Mr. David Daniels, chief executive officer, of this company. No changes to the email addresses of these
contacts are needed in IBEAM.
Compliance Assurance Visit:
1. The purpose of this site visit was to conduct a compliance assurance visit (CAV). Daniels
Woodcarving Company, Inc. manufactures wood furniture parts and frames. This company
currently operates this facility 8 to 10 hours per day (40 to 48 hours per week), Monday through
Thursday, 50 weeks per year. Mr. David Daniels, chief executive officer, accompanied me
during this visit.
2. Facility Contact Information:
During the inspection,I verified the facility contact information in IBEAM with Mr.Daniels.
No changes to the facility contact information are needed in IBEAM.

Daniels Woodcarving Company; Inc.
February 21, 2019
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3. Compliance history file review:
No problems have been noted in the last five years by DAQ prior to this visit. The current
compliance status is discussed in the following sections.
4. Source Observations:
This company has two bagfilters (6,924 square feet of filter area, each) installed on woodworking
equipment; one closed-loop transfer cyclone; and one seasonal-use biomass(wood-fired) boiler
rated at 2.4 million Btu per hour. These sources were installed after July 1, 1971 and are subject
to the 20% opacity limit for visible emissions when averaged over a six-minute period.
The woodworking equipment consisting of various band saws, routers, molders, shapers and
sanders are vented to the bagfilter(6,924 square feet of filter area) in the old building and to
another bagfilter(6,924 square feet of filter area) in the newer building. Both bagfilters exhaust
to a closed-loop transfer cyclone(size unknown). The woodwaste is dropped through a chute
from the closed-loop cyclone into the first open top tractor trailer and then augered into the
second open top tractor trailer. Mr. Daniels stated that there are augering systems inside of each
tractor trailer. The woodworking equipment,two bagfilters and transfer cyclone were in
operation. I observed no visible emissions from these sources.
The exhaust of each bagfilter is either returned through two separate vents to the inside of the old
and newer buildings or outside through a horizontal and uncapped stack. The two bagfilters were
exhausting inside for the purpose of heating the old and newer buildings during colder weather.
This company uses a wood-fired boiler(manufacturer,Hurst Boiler and Welding Co., Inc.; mfg.
serial# FB32530; 1725 steam lbs. hr. and 1983, year built)to steam heat this facility. The
maximum heat input of this boiler is rated at 2.4 million Btu per hour. The scrap hardwood
blocks are manually placed inside of the boiler. The wood-fired boiler functions like a fireplace.
There are no burners or system controls on the boiler. A pressure gauge and grates are installed
on this boiler. Mr. Daniels stated that the boiler operates 20 to 30 days per year when the
temperature is below 32 degrees Fahrenheit. The wood-fired boiler is subject to the requirement
of 40 CFR Part 63, Subpart JJJJJJ(6J) "National Emission Standards for Hazardous Air
Pollutants (NESHAP) for Area Sources: Industrial, Commercial, and Institutional Boilers."
During this visit,the wood-fired boiler was in operation with visible emissions ranging from 5%
to 10% opacity.
This company uses two wood glues (Assembly High Tack and Assembly 233) by the
manufacturer, Franklin International, to assemble the furniture frames and parts. Copies of the
SDS are located in the file of this facility. The wood glue is applied to the frames and parts in a
horizontal tray. The Assembly High Tack glue has 0.089 pounds per gallon of VOC as indicated
on the SDS. The Assembly 233 glue has 0.0196 pounds per gallon of VOC as indicated by the
SDS. The Assembly High Tack glue usage was 5897 pounds in 2017 and 2425 pounds in 2018.
The Assembly 233 glue was 10,692 in 2017 and 13,117 in 2018. The actual emissions form the
gluing operations are less than five tons per year and exempt from permitting per 15A NCAC 2Q
.0102 (h)(3).
This office has not received any fugitive dust emissions complaints regarding this facility. This
company has paved roads at this facility. During this visit, I observed no fugitive dust from this
facility. I discussed with Mr. Daniels if any excess emissions had occurred at this facility since

Daniels Woodcarving Company, Inc.
February 21, 2019
Page 4
the last inspection on November 8,2017. Mr. Daniels stated that no excess emissions had
occurred at this facility.
5. NSPS/NESHAP Review:
The manufacturing of wooden furniture parts and frames is currently not subject to any NSPS
rules. The seasonal biomass (wood-fired)boiler is not subject to 40 CFR Part 60, Subpart De-
"Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating
Units" because the heat input capacity of this boiler is less than 10 million Btu per hour.
The biomass(wood-fired)boiler rated at 2.4 million Btu per hour was built in the year 1983.
This wood-fired boiler is considered an existing source in 40 CFR Part 63, Subpart JJJJJJ or 6J,
"National Emission Standards for Hazardous Air Pollutants (NESHAP) for Area Sources:
hndustrial, Commercial, and Institutional Boilers," because it commenced construction on or
before June 4,2010. The NESHAP Subpart 6J defines a seasonal-use boiler as being shutdown
for a period of at least 7 consecutive months or 210 consecutive days each 12-month period due
to seasonal conditions except for periodic testing. The periodic testing can not exceed a
combined total of 15 days during the 7 month shutdown. This wood-fired boiler meets the
definition of seasonal-use since it operates approximately 20 to 30 days per year and the heat
input is less than or equal to 5 million Btu per hour. This facility is required by NESHAP 6J to
keep days of operation per year for the seasonal boiler. I advised Mr. Daniel to record the days of
operation per year for the wood-fired boiler.
The initial notification form had to be submitted by January 20, 2014. NC DAQ received the
initial notification form on October 10, 2011, stating that existing wood-fired boiler(ID No. B-1)
at this facility is subject the NESHAP rule. The notification of compliance status(NOCS) for the
boiler tune-up had to be submitted by July 19,2014 (previous 6J rule deadline dates were July 19,
2012 and July 19, 2013 by USEPA). The NOCS was received by MRO DAQ on May 9,2012.
Copies of these notifications are being kept by this facility.
The one-time energy assessment for boilers with a heat input greater than or equal to 10 million
Btu per hour was due by March 21, 2014. The energy assessment requirement does not apply to
this existing boiler since the heat input capacity of this boiler is not 10 million Btu per hour or
greater.
The NESHAP 6J rule does not have emission limits on the existing wood-fired boiler. This
company must implement a tune-up program as a management practice. An initial boiler tune-up
was required by March 21,2014 (previous 6J rule deadline dates were March 21, 2012 and
March 21, 2013 by USEPA). The initial tune-up of this,boiler was conducted on December
23,2011. This boiler is required by NESHAP Subpart 6J to conduct a tune-up every 5 years or
within 61 months of the previous tune-up.
The boiler operates like a fireplace so the tune-up activities,are minimal. There is no burner or
air-fuel ratio to adjust to optimize combustion and no concentrations of carbon monoxide or
oxygen to be measured. Mr. Daniels stated that this boiler is steam heated and the NC
Department of Labor inspects this boiler once a year in the Spring. According to the records
provided by Mr. Daniels, the tune-ups/inspections of the boiler were conducted on 3/20/18;
3/21/17; 3/24/16; and 11/1/13.
This company must prepare a compliance certification report by March 1 every five years,

Daniels Woodcarving Company, Inc.
February 21, 2019
Page 5
maintain it on site unless specifically requested by NC DAQ, and then subsequent certifications
prepared by March 1 of the year following the tune-up. The compliance certification reports were
dated 3/20/18; 3/21/17; 3/24/16; and 11/1/13. The records are being maintained on-site of the
tune-up/inspections on the boiler. If this boiler experiences any deviations from the applicable
requirements,then the compliance certification report must be submitted by March 15 of the year
following the tune-up. Mr. Daniels stated that the wood-fired has not experienced any deviations.
This company has no emergency or peak shaving generators, fire pump engines or gasoline
storage tanks at this facility.
6. Exemption Qualification:
On October 17,2016,this facility submitted a request to rescind Air Permit No. 05446R09, since the
actual facility-wide emissions of particulate matter(PM10), sulfur dioxide, nitrogen oxides,volatile
organic compounds, carbon monoxide, hazardous air pollutants (HAP) and toxic air pollutants
(TAP), each are less than five tons per year and the total actual aggregate emissions of these
pollutants are less than ten tons per year. This facility qualifies for this exemption since it is not
required to have a permit pursuant to 15A NCAC 2Q .0500.
This company provided information with the permit rescission request on the actual facility-wide
emissions from the wood-fired boiler and woodworking equipment for calendar years 2011 through
2015. The highest wood usage from the boiler was 6 tons. The highest board feet from the
woodworking operations was 680,000. The highest total emissions from the wood combustion and
woodworking operations were PM10=0.060;NOx=0.020; CO= 0.030; total HAPs=0.0019; and
total aggregate=0.11.
MRO DAQ sent a letter dated November 4, 2016 to this company exempting this facility from
permitting, since the facility-wide actual emissions of particulate matter(PM10), sulfur dioxide,
nitrogen oxides, volatile organic compounds, carbon monoxide, hazardous air pollutants(HAP and
toxic air pollutants (TAP), each are less than five tons per year and the total actual aggregate
emissions of these pollutants are less than ten tons per year per 15A NCAC 2Q .0102 (d) and then
rescission of its air permit.
Mr. Daniels stated that the board feet from the woodworking operations was 700,000 in 2017 and
800,000 in 2018 and the wood usage from the boiler was 3 tons to 6 tons in 2017 and 2018. The
emissions from the wood combustion and woodworking operations were below the exemption
thresholds. The actual facility-wide emissions of all pollutants indicate that this facility still
qualifies for exemption under 15A NCAC 2Q .0102(d). This facility has not changed or modified
the equipment to increase emissions above the exemption thresholds since the permit exemption
and recession request.
7. Compliance determination:
Based on my observations, this facility appeared to be in compliance with the air quality rules
(2D .0521-visible emissions; 2D .0535-excess emissions; 2D .0540-fugitive dust emissions and
2D .1111 Maximum Achievable Control Technology(MALT) as promulgated in 40 CFR Part 63,

Daniels Woodcarving Company, Inc.
February 21, 2019
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Subpart JJJJJJ (6J), NESHAP for area sources or boiler GACT 6J at the time of the visit. The
compliance assurance visit checklist is attached on page 6.
DLC:lhe
c: MRO File
https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00039/[NSPECT_20190221_CAV.docx

Daniels Woodcarving Company, Inc.
February 21, 2019
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Compliance Assurance Visit Checklist ev.11/03/16
Facility Name:Daniels Woodcarving Company,Inc.
Physical Site Address: 2325 Highway 90 East
City:Taylorsville Zip Code: 28681 County: Alexander
Facility Contact:David Daniels Title: Chief Executive Officer
Phone No.:[phone]
Mailing Address:2325 Highway 90 East,Tyalorsville,NC 28681
Facility Contact Email Address: [e-mail]
Is the facility contact the person that you met? If not,fill out the following:
Contact Name:Same Title:
Phone No.:
Mailing Address:
Email Address:
Safety requirements:safety shoes(yes/no)-safety glasses(yes/no)-hearing protection(yes/no)-hardhat(yes/no)
safety vest(yes/no) other(please describe):
Normal operating schedule(hr/d,d/wk,wk/yr): B-9hr/dor4D-48hr/wk,4d/wk,50wk/yr
Opacity(%)-indicate any non-zero opacities observed: 0%from woodworking&5-10%from wood-fired boiler
Odors-indicate if any objectionable odors were detected beyond the property boundary: None
Fugitive dust-indicate whether fugitive dust was observed leaving property boundary: None
Since last inspection,have there been any changes in equipment or operation? None
Throughput and/or fuel usage with units: Woodworking:CY 2018=8D0,000 board feet;CY 2017=700,D00 board feet;
Wood-fired boiler:CY 2017&2018=3 tons to 6 tons maximum
Control device(s)(list): Two bagfilters(6,924square feet of filter area,each)Installed on woodworking
equipment;Transfer cyclone(size unknown)installed on both bagfilters
Properly operated and maintained? Yes
For a permit exempt facility found to be improperly operating or maintaining plant equipment:1)provide compliance
assistance as a first option;2)initiate enforcement action in egregious/repeat cases;3)re-evaluate facility's emissions
using a more representative control efficiency/emission factor;4)If re-evaluated actual emissions result in a
classification/registration change,follow enforcement guidelines for operation without a permit/registration;and
5)increase compliance visit frequency.
Notes or calculation space:
Other Sources:Seasonal-use wood-fired boiler that produces steam(2.4 million Btu per hour heat input rate)for comfort
heating;Franklin International glue usage:Assembly High Tack CY 2018=2,425 pounds&CY 2017=5,897 pounds and
Assembly 233 CY 2018=13,117 pounds&CY 2017=10,692 pounds
Permit Exemption:
•Actual emissions from the previous year(s)(and projected actual)of PM10,502,NOx,VOCs,CO,HAPs,and TAPS
are each<5 tpy and whose actual total aggregate of these emissions are<10 tpy
•Can be subject to 40 CFR Part 63(MACT or GACT)and 40 CFR Part 60(NSPS)
Boilers:
ID No. #1 #2 #3 #4
Installed or last modified date 1983 built
Size(mmBTU heat input) 2.4 million Btu/hr input
Primary/backup fuel: Wood
Fuel used(annual) 3 to 6tons
NSPS Subpart Dc subject? No<10 million Btu/hr input
NSPS Subpart Dc boiler if>10 mmBtu/hr and<100 mmBtu/hr installed or modified afterJune 9,1989.
Gas only Dc subject boilers:have they submitted initial notification(only requirement)? Yes/No/NA
Gas/fuel oil Dc subject boilers:records kept of each fuel type and startup notification for each fuel? Yes/No/NA
Fuel oil certification required for Dc subject boilers(0.5%max S content).Are copies kept? Yes/No/NA
If fuel oil Dc subject boiler>30 mmBtu/hr,was opacity testing performed on schedule based on results?` Yes/No/NA
`If VE=01%then done annually,<=5%done semiannually,<=100%done quarterly,>10%done every 45days.
GACT 6J Gas Curtailment option claimed? Yes/No
If no,has a one-time energy assessment been performed. Yes/No/NA
If no,are tune-ups being done biennially(25 months since last tune-up)? Yes/No/NA
If yes,are records kept for natural gas curtailment and testing less than 48 hours per year. Yes/No/NA
Woodworking: %each must total 100
Wood waste(tpy): Planing
or Sawing/chipping 70
Throughput(board ft/yr):CY 2018=800,000 bd.ft. Rough sawing
CY 2017=700,000 bd.ft. Fine sawing
Wet/dry wood?Dry Wood Milling(&hog)
Bagfilter or cyclone?Bagfilters(6,924 sq ft,each) Molding
Transfer cyclone(size unknown) Sanding 30