(I) DIRECTIONS TO SITE: The facility is located on Rte. 109 between Troy and Mt Gilead. From FRO, follow Rte. 24 west through Moore County and through Troy. About 3 miles past Troy, bear left (south) onto Rte. 109. The facility is on the left, ˝ mile past Jordan Lumber. Turn left before the gate guard into the visitor’s parking lot. The receptionist is through the door toward the right side of the admin building.
(II) FACILITY DESCRIPTION: The plant manufactures high-density fiberboard for use in furniture, walls, and flooring. Raw materials are Southern Yellow Pine chips from Jordan Lumber and urea-formaldehyde resin. These chips are turned into fibers and coated with glue, then formed into fiberboard of varying thicknesses and heated to cure. There are also woodworking operations (sawing and sanding) and coating operations, using very low-solvent materials, on the fiberboard product. The heating plant consists of wood and sawdust fired burners rated at 182 mmBtu/hr total and, as secondary heat sources, three No. 2 oil burners (in the same fire box) rated at 157 mmBtu/hr total, and three natural gas burners (in the same fire box) rated at 157 mmBtu/hr. The principal operating scenario is combustion of wood, supplied by Jordan and from Unilin’s own processes (sawing, sanding, fugitive/off-spec fiber).
(III) INSPECTION SUMMARY: On 15 June 2006, I, Robert Kennedy of FRO, met Mr. Bob Pierce, Safety and Environmental Coordinator. Mr. Pierce reported that Paul De Fraeye is no longer associated with the facility; Mr. Heyen is now the Authorized Contact. Mr. Pierce conducted a brief plant tour, provided the required records and attended the post- inspection meeting. The boiler was operating on wood waste. The dryer/refiner and board line were operating; the wood working operation was not operating; the coating line was operating. The current permit for this inspection is temporary, and in “300-series permit” format. Unilin has submitted the Title V permit application, and the initial Title V permit is at the draft status. After the inspection, Mr. Pierce and I discussed the draft Title V air permit. We focused on the changes in recordkeeping and reporting, including the VOC calculation.
(IV) PERMITTED EMISSION SOURCES:
A. One natural gas-fired or No. 2 fuel oil-fired regenerative thermal oxidizer (ID No. CD-RTO) installed in series with aqueous assisted fiber removal chamber installed on the combined emissions of:
1. One multicylone (ID No. CD-01) and a Selective Non-Catalytic Oxidation (SNCR) unit installed on one NSPS heating plant (ID No. ES-HP) consisting of one wood fired boiler (130 million Btu per hour); one sanderdust duct burner system (52 million Btu per hour); two No. 2 fuel oil fired auxiliary burners (heat input of 41 million Btu per hour heat input each); and one No. 2 fuel oil fired auxiliary burner (75 million Btu per hour heat input); two natural gas fired auxiliary burners (heat input of 41 million Btu per hour heat input each); and one natural gas fired auxiliary burner (heat input of 74 million Btu per hour heat input),
2. One blowline flash-tube dryer (ID No. ES-DRY),
3. One hot oil heated continuous board press (ID No. BP-01),
4. One pressurized refiner (ID No. ES-RFN),
B. Fugitive emission sources including:
1. board breaker and conveyer (ID No. F-08),
2. board cooling and stacking area (ID No. F-BC),
C. One bagfilter (3,702 square feet of filter area, ID No. FF21) installed in series with one simple cyclone (140 inches in diameter, ID No. CY21) installed on the dried fiber grader system #1 (ID No. ES-21),
D. One bagfilter (3,702 square feet of filter area, ID No. FF22) installed in series with one simple cyclone (140 inches in diameter, ID No. CY22) installed on the dried fiber grader system #2 (ID No. ES-22),
E. One bagfilter (15,069 square feet of filter area, ID No. FF23) installed in series with two parallel simple cyclones (124 inches in diameter, ID No. CY23A and 157 inches in diameter ID No. CY23B) installed on the mat trimmings return air system (ID No. ES-23),
F. One bagfilter (6,150 square feet of filter area, ID No. FF31) installed on the fine sanderdust pneumatic conveyer system (ID No. ES-31),
G. One bagfilter (8,680 square feet of filter area, ID No. FF32) installed on the coarse sanderdust pneumatic conveyer system (ID No. ES-32),
H. One bagfilter (4,650 square feet of filter area, ID No. FF33) installed on the sawing and cutting pneumatic conveyer system (ID No. ES-33),
I. One bagfilter (3,020 square feet of filter area, ID No. FF34) installed in series with one simple cyclone (98 inches in diameter, ID No. CY34) installed on the press trim saw and dust collection system (ID No. ES-34),
J. Four NSPS fixed roof resin storage tanks (30,000 gallon capacity each, ID Nos. ES-40a, b, c and d) and one fixed roof resin storage tank (25,000 gallon capacity, ID No. ES-40e),
K. One NSPS fixed roof wax storage tank (25,000 gallon capacity, ID No. ES-40f),
L. One diesel-fired 500 kw emergency generator (ID No. ES-41), and
M. One rotographic surface coating line (ID No. ES-50)
(V) APPLICABLE AIR QUALITY REGULATIONS:
A. 15A NCAC 2D .0503, PARTICULATE FROM FUEL-BURNING INDIRECT HEAT EXCHANGERS. The particulate from the heating plant (ES-HP) when combusting oil is limited to 0.29 lbs/mmBtu, or 52.8 lbs/hr.
IN COMPLIANCE. The AP-42 particulate emission factor for this unit, equipped with a wet scrubber, is 0.3 lbs/hr.
B. 15A NCAC 2D .0504, PARTICULATES FROM WOOD BURNING INDIRECT HEAT EXCHANGERS. The sole applicable source is the heating plant (ES-HP) when combusting wood chips, sawdust or fibers. The standard is 0.37 lb/mmBtu, or 67.3 lbs/hr.
IN COMPLIANCE. The AP-42 particulate emission factor is 15.1 lbs/hr. The August 2002 performance test reported 11.5 lbs/hr; the March 2003 performance test reported 8.01 lbs/hr.
C. 15A NCAC 2D .0512, PARTICULATES FROM WOOD PRODUCTS FINISHING PLANTS. Source ID Nos. ES-21, ES-22, ES-23, ES-31, ES-32, ES-33 and ES-34 shall not discharge particulate matter without providing adequate ductwork and properly designed collectors.
IN COMPLIANCE. All bag filters, cyclones, and ductwork appear to be effective.
D. 15A NCAC 2D .0515, PARTICULATE FROM MISCELLANEOUS INDUSTRIAL PROCESSES. Sources ID Nos. ES-HP, ES-DRY and ES-RFN shall be limited to particulate emissions no greater than 55 * P0.11 - 40.
IN COMPLIANCE. The use of control devices and control systems result in negligible PM emissions.
E. 15A NCAC 2D .0516, SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES. The affected sources are the heating plant (ES-HP) and the emergency generator (ES-41). The regulatory limit is 2.3 lbs/mmBtu.
IN COMPLIANCE. NSPS limits the sulfur content of the fuel oil to 0.5% by weight, resulting in SO2 emissions of 0.5 lbs/mmBtu, well below the limit. Unilin is actually burning low sulfur oil that is certified at 0.2% sulfur by weight. Sulfur dioxide from wood combustion is a trace emission.
F. 15A NCAC 2D .0521, CONTROL OF VISIBLE EMISSIONS. The visible emission from all sources except ES-HP is limited to 20%; the visible emission from ES-HP limited to 20% in NSPS, Subpart Db.
IN COMPLIANCE. During the inspection, I observed VE from the boiler in the 5% – 10% range while the COM reported 7-8%. I observed 0% VE from all other sources.
G. 15A NCAC 2D .0524, NSPS 40 CFR PART 60, SUBPART Db. STANDARDS OF PERFORMANCE FOR INDUSTRIAL/COMMERCIAL/INSTITUTIONAL STEAM GENERATING UNITS. The affected source is the heating plant (ES-HP). Requirements include: (1) notifications; (2) initial performance testing; (3) particulate emission rate limit of 0.1 lb/mmBtu; (4) 20% opacity limit; (5) 10% capacity factor and 0.3 weight percent nitrogen content limit for non-wood fuels; (6) fuel sulfur limit of 0.5% by weight with accompanying fuel certification; (7) a maximum 975,404 gallons of fuel oil combusted each 12 months and a maximum 10% annual capacity factor; (8) record keeping and reporting daily fuel usage by type, and (9) installation, calibration, maintenance and operation of the COM.
IN COMPLIANCE. The notifications have been received by FRO; the initial performance testing was conducted on 5 August 2002 and retested on 13 March 2003. The August 2002 testing demonstrated compliance with the particulate emission rate of 0.1 lb/mmBtu. During the inspection, I observed VE from the RTO stack in the 5-10% range; the COM reported VE in the 7-8% range. Recordkeeping and reporting were in order. The COM was installed on 18 August 2003 and certified for operation on 7 October 2003; it is calibrated quarterly by Monitoring Solutions; I reviewed the instantaneous VE value of the COM and also reviewed one of the strip charts (approximately 10 days data).
H. 15A NCAC 2D .0524, NSPS 40 CFR PART 60, SUBPART Kb. STANDARS OF PERFORMANCE FOR VOLATILE ORGANIC LIQUID STORAGE VESSELS. Requirements depend on storage capacities and vapor pressures.
IN COMPLIANCE. The Permittee maintains engineer prints on the storage tanks and data sheets on the resin showing exemption from Kb requirements.
I. 15A NCAC 2D .0530, PREVENTION OF SIGNIFICANT DETERIORATION. The subject sources are the heating plant (ES-HP), the board press (BP-01), the flash-tube dryer (ES-DRY) and the RTO (CD-RTO). The requirements include: (1) maintain a 3-hour block average firebox temperature in the heating plant at or above 1500 degrees F; (2) maintain a 3-hour block average static pressure at the inlet of the scrubber in the rage of negative 0.5 to 2.0 inches of water; (3) limit the flash-tube dryer to a maximum of 36 tons of fiber per hour; and (4) limit the press production to a maximum of 24,000 square feet of board (3/4 inch basis).
IN COMPLIANCE. During the inspection, I reviewed the daily logs for the 3-hour block averages for firebox temperature and inlet static pressure; I also reviewed the logs for the flash-tube dryer loading and the press production.
J. START-UP RESTRICTIONS. The Permittee is allowed to: bypass the RTO on heating plant startup for no more than 12 hours per 24-hour period; and bypass the flashtube dryer and RTO during charging of the refiner for no more than 1 hour per 24-hour period. The Permittee shall record the number of hours the heating plant and refiner are operated in startup bypass.
IN COMPLIANCE. During the inspection, I reviewed the records of bypass operation and did not discover an exceedance. However, the records were graphical and not ease to read. Mr. Pierce and I discussed tabularizing the records for ease of review, and Mr. Pierce state that Unilin is in the process of purchasing a digital device to record numerous data point including time operating under bypass. .
K. HEATING PLANT OPERATION - The Permittee is allowed to operate the heating plant (ES-HP) without the SNCR unit (CD-SNCR),
IN COMPLIANCE – The SNCR has been removed from the heating plant.
L. 15A NCAC 2D .0958(c) WORK PRACTICES FOR SOURCES OF VOCs. The Permittee shall follow work practices to minimize the fugitive emissions of VOCs.
IN COMPLIANCE. During the inspection, I did not notice any violations of 2D .0958(c). The facility uses very little solvent, limited to maintenance and cleaning.
M. 15A NCAC 2D .0535, EXCESS EMISSIONS REPORTING AND MALFUNCTIONS. The Permittee is required to promptly report excess emissions to DAQ.
IN COMPLIANCE. Unilin has twice reported excess emissions when the RTO was not operational, in September 2003 and July 2004. During a 10 day period in November and December of 2005 under a temporary permit, Unilin operated without the RTO during a rebuild of the RTO unit shell.
N. 15A NCAC 2D .1112, CASE-BY-CASE MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT). The Permittee shall demonstrate a 90% reduction of formaldehyde, methanol and VOCs in the RTO, maintain a 3-hour block average firebox temperature in the heating plant at or above 1500 degrees F, and maintain a 3-hour block average static pressure at the inlet of the scrubber in the rage of negative 0.5 to 2.0 inches of water.
IN COMPLIANCE. The August 2002 testing has shown destruction is consistently in the 93% range (93.9, 93.8 and 93.4). During the inspection, I reviewed the daily logs for the 3-hour block averages for firebox temperature and inlet static pressure.
O. 15A NCAC 2D .1100, TOXIC AIR POLLUTANT LIMITATION AND REPORTING. The emissions of acrolein, formaldehyde and phenol are limited to hourly rates based on the air toxic compliance demonstration. The RTO emission limit for formaldehyde is 10.9 lbs/hr; acrolein is 0.0823 lbs/hr; phenol is 0.84 lbs/hr.
IN COMPLIANCE. The March 2003 performance test reported the formaldehyde emission rate at 2.75 lbs/hr. The 2004 EI reports emissions of acrolein and phenol at levels of 65% or less of the hourly limits.
P. 15A NCAC 2Q .0711, EMISSION RATES REQUIRING A PERMIT. The Permittee shall not exceed the hourly, daily and annual TPERs emission rate for acetaldehyde, MEK, MIBK and styrene. The permitted limit for acetaldehyde is 6.8 lbs/hr; MEK is 78 lbs/day and 22.4 lbs/hr; MIBK is 52 lbs/day and 7.6 lbs/hr; styrene is 2.7 lbs/hr.
IN COMPLIANCE. The 2004 EI reports emissions of acetaldehyde, MEK, MIBK and styrene at levels of less than 1% for these toxics limits except for the 5% level for styrene.
Q. 15A NCAC 2D .0611 BAGFILTER AND AIR FILTER REQUIREMENTS. The Permittee shall perform periodic inspections and an annual internal inspection of bagfilters and air filters.
IN COMPLIANCE. During the inspection, I reviewed the I&M records; the Permittee performed an annual and monthly periodic inspections on each baghouse.
R. 15A NCAC 2D .0611 CYCLONE REQUIREMENTS. The Permittee shall perform periodic inspections and an annual inspection of all cyclones.
IN COMPLIANCE. During the inspection, I reviewed the I&M records; the Permittee performed monthly inspections on each cyclone.
S. 15A NCAC 2D .0611 THERMAL OXIDIZER REQUIREMENTS. The Permittee shall perform periodic inspections and an annual internal inspection of the RTO.
IN COMPLIANCE. During the inspection, I reviewed the I&M records; the Permittee performed an internal inspection and numerous other inspections on the RTO. Mr. Pierce reported that the RTO looked much better during the last internal inspection though there are small cracks to be repaired in a support beam in one can. The RTO exhibited rusting areas on the outside of the can walls, but Mr. Pierce assured me that the walls were structurally sound and would be re-enforced and/or refinished in the future.
T. 15A NCAC 2D .0611 MULTI-CYCLONE REQUIREMENTS. The Permittee shall perform periodic inspections and an annual inspection of all multi-cyclones.
IN COMPLIANCE. During the inspection, I reviewed the I&M records; the Permittee performed a monthly external inspection on the multi-cyclone.
(VI) PERMIT-EXEMPT EMISSION SOURCES:
A. Raw material unloading, ID No. F-1,
B. Covered shavings building, ID No. F-2,
C. Roundlog chips handling/storage, ID No. F-3,
D. Sawmill chip handling storage, ID No. F-4,
E. Fuel chips handling storage, ID No. F-5,
F. Overflow chip handling, ID No. F-6,
G. Chip handling infeed to process, ID No. F-7, and
H. Sanderdust truck loading, ID No. F-35
(VII) FIVE YEAR COMPLIANCE HISTORY:
02/08/02: FRO issued an NOV/NRE for open burning of construction debris.
07/12/02: FRO issued an NOV/NRE for failure to conduct initial source test on time.
08/14/02: FRO issued an NOV/NRE for failure to install opacity monitor prior to stack testing.
10/25/02: FRO issued an NOV/NRE for failure to meet emissions and performance standards.
01/29/03: FRO issued an NOV/NRE for failure to meet permit standards of demonstrating compliance for PM10 and HAP emissions, and opacity by COM.
11/17/03: FRO issued an NOV for operation the board production line without the primary control device (RTO) for over five days.
07/13/04: FRO issued an NOV/NRE for operation of the board production line without their primary control device (RTO).
(VIII) CONCLUSIONS AND RECOMMENDATIONS:
During this inspection, the Unilin Flooring, NV appeared to be operating in compliance.