1030510 84711 FACILITY: ADDRESS: Marshfield DoorSystems, Inc. PERMIT ID: Bolection Door - Largo Division DISTRICT: Southwest CONTACT PHONE: 11200 69th Street North Largo, FL ARM S NO : 727-546-1260 Expiration Date: 5/5/2016 Renewal Date: 3/6/2016 Test Due Date: 8/19/2000 PERMIT NO: 1030510-004-AF 1030510 002 2772 EMISSION UNIT DESCRIPTION : Manual Production Line :Six production areas: cutting, fabrication, machinery, prep, assembly, pre-hang. The process has table saws, routers, sanders, planers, sharpers, etc. vented to the east side of Donaldson DF04-1444 cartridge collector INSPECTION DATE: February 5, 2013 INSPECTION TYPE: Initial ARMS INSPECTION TYPE: INS1 INS2 Re-inspection INS3 COMPLIANCE STATUS: FUI Complaint IN Drive-by M N C SNC Quarterly A. General Review: 1. Permit File Review Comments: 2. Introduction and Entry Comments: 3. Is the Responsible Official/Authorized Representative still: JoAnne Firestone? Comments: The Responsible Official/Authorized Representative’s e-mail is: dana.levarn@mdrsys.com 4. Is the facility contact still: Dana Levarn? Comments: The facility contact’s e-mail is: dana.levarn@mdrsys.com I N MNC S N C Yes No Yes No Yes No Yes No B. Specific Conditions: Permitting note: This permit became effective on 5/6/11. It renews Federally Enforceable State Operating Permit (FESOP) 1030510-002-AF, and also removes the specific condition that limits the finishing process to the use of acrylic water based primer only. Painting operations at this facility will qualify for a categorical exemption under Rule 62-210.300(3)(a).27., F.A.C. This change affects both emissions units. A.1. Permitted Capacity: The maximum production rate for the fiberboard door manufacturing operation shall not exceed 850 doors per day. [Rule 62-210.200(PTE), F.A.C.; Construction Permit 1030510-001-AC] Comments: Based on a record review, the facility never exceeded 850 doors/day. A copy of the monthly data for Dec, 12’ is attached to the inspection report, EU 001. A.3. Visible Emissions: Visible emissions from each section of the dust collector system shall not exceed 20% opacity, however, in order to provide reasonable assurance that each section is being properly operated, visible emissions from each section should not exceed 5% opacity. Exceedance of the 5% limit shall not be considered a violation in and of itself, but an indication that the dust collector is not functioning properly. h:\users\Templates\Generic Page 1 [Rule 62-296.320(4)(b)1., F.A.C.; Construction Permit 1030510-001-AC] Comments: No visible emissions were observed during the inspection from EU 002 of the dust collector. A.4. Visible Emissions Tests: During each federal fiscal year (October 1st to September 30th), each section of the dust collector shall be tested to demonstrate compliance with Specific Condition No. A.3. All sources controlled by each section of the dust collector shall be in operation during testing. [Rule 62-297.310, F.A.C.; Construction Permit 1030510-001-AC] Comments: The visible emissions test performed on 9/27/12 indicated the opacity = 0%. A.5. Test Requirements: Tests shall be conducted in accordance with the applicable requirements specified in Appendix D (Common Testing Requirements) of this permit. Rule 62-297.310, F.A.C.] [ Comments: The facility meets the provision of the condition. The test is performed for 30 minutes. A.6. Test Method(s): Required tests shall be performed in accordance with the following reference method. Method(s) Description of Method and Comments 9 Visual Determination of the Opacity of Emissions from Stationary Sources [Rules 62-204.800 and 62-297.100, F.A.C.; and Appendix A of 40 CFR 60] Comments: Marshfield Doors met the Method 9 requirements for the 9/27/12 test. A.7. Test Notification: The permittee shall notify the Compliance Authority in writing at least 15 days prior to any required tests. The notification must include the following information: the date, time, and location of each test; the name and telephone number of the facility’s contact person who will be responsible for coordinating the test; and the name, company, and the telephone number of the person conducting the test. Permitting Note: The notification should also include the relevant emission unit ID No(s)., test method(s) to be used, and pollutants to be tested.} [Rules 62-4.070(3) and 62-297.310(7)(a)9., F.A.C.] Comments: Air Quality received the notification letter on 9/11/12, 16 days prior to the test. A.8. Test Reports: The permittee shall prepare and submit reports for all required tests in accordance with the requirements specified in Appendix D (Common Testing Requirements) of this permit. The actual production rate (in number of doors per hour) for the test period shall be included in the test report for each test. Failure to submit the actual production rate for the test period and a copy of the daily log for the test day with the test report may invalidate the test and fail to provide reasonable assurance of compliance. [Rule 62-297.310(8), F.A.C.; Construction Permit 1030510-001-AC] Comments: Under Appendix D, the facility notes its process rate during the VE test. 15 doors were produced during the 30 minute test. 31 doors/hr. h:\users\Templates\Generic Page 2 A.9. Daily Log: In order to demonstrate compliance with Specific Condition No. A.1., the permittee shall maintain appropriate daily records of the production lines. A daily operation log shall at a minimum contain the following: a. Date, Facility Name, and Emission Unit ID Nos.; b. Total number of doors processed through automated conveyorized line; c. Total number of doors processed through manual production line; and d. Total number of doors processed through both production lines. Daily records shall be completed within 3 business days. These records shall be maintained at the facility for a minimum of the most recent three (3) year period and made available to the Permitting and Compliance Authorities upon request. [Rule 62-4.070(3), F.A.C.] Comments: As an example 12/27/12; Door line #1 automated line = 131 doors produced Door line #2 manual line = 24 doors produced Total doors produced = 155 doors produced The daily records are completed the same day. The facility will be switching to station terminals that will allow staff to update its daily production records. The records have been on-site since 2006. A copy of this record is attached to the inspection report, EU 001 A.10. Operation and Maintenance (O & M) Plan for Particulate Matter Control: The permittee shall maintain and implement an O & M Plan for the dust collector to include a schedule for the maintenance and inspection of the control device, collection systems, and auxiliary equipment. Records of inspections, maintenance, and performance data of the control device and auxiliary equipment shall be retained at the facility for a minimum of two (2) years and shall be made available to the Compliance Authority upon request. The O&M Plan may be amended with the prior approval of the Compliance Authority. At a minimum, the O&M Plan shall include: a. The operating parameters of the pollution control device. b. Timetable for the routine maintenance of the pollution control device as specified by the manufacturer. c. Timetable for routine periodic observations of the pollution control device sufficient to ensure proper operations. d. A list of the type and quantity of the required spare parts for the pollution control device, which are stored on the premises of the permit applicant. e. A record log which will indicate, at a minimum: 1. When maintenance and observations were performed; 2. What maintenance and observations were performed; 3. Who performed said maintenance and observations; and 4. Acceptable parameter ranges for each operational check. [Rule 62-4.070(3), F.A.C. and Pinellas County Code, Section 58-128(a)] Comments: The facility keeps maintenance records. A copy of the record for 12/28/12 is attached to the compliance file. Specifically, what was checked whether it’s the purge operation, collector auger, transfer auger, dust shed auger or trailer level, when it was checked and who checked it. The dust collector pressure is checked. The checks occur every 3 hours/work day. The facility meets the provisions of the condition. A copy of this record is attached to the inspection, EU 001. h:\users\Templates\Generic Page 3 Valid Permit [Rule 62-210.300] Changes to Facility/emission unit [Rule 62-210.300] Does the emission unit description above match what the facility is operating (Number of emission units or points, model number and serial number, etc.) Yes No Comments: C. Other: Pollution Prevention Activities P2 Brochure; P2 Manual; P2 Checklist P2 Handouts Provided: Have any emissions reductions occurred Yes / No Chemical Substitution; Equipment Changes; Process Changes Chemical/Material Reuse; On-site Recycling; Other: Comments: There were no pollution prevention activities during the compliance year. Closing Conference: Inspector(s): Jeffrey Morris, Pinellas County, Air Quality Division Signature(s): ACCESS? Date: ARMS? h:\users\Templates\Generic Page 4 Date: