AQ_F_0400030_20180313_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Columbus McKinnon Corp-Wadesboro Operations
NC Facility ID 0400030
Inspection Report County/FIPS:Anson/007
Date: 03/21/2018
Facility Data Permit Data
Columbus McKinnon Corp-Wadesboro Operations Permit 03671/R10
2020 Country Club Road Issued 8/20/2013
Wadesboro,NC 28170 Expires 7/31/2018
Lat: 34d 56.5990m Long: 80d 3.1730m Classification Small
SIC: 3536/Hoists,Cranes,And Monorails Permit Status Active
NAILS: 333923/Overhead Traveling Crane,Hoist,and Monorail System Current Permit Application(s)None
Manufacturing
Program Applicability
Contact Data
SIP
Facility Contact Authorized Contact Technical Contact
MACT Part 63: Subpart 6H
Phillip Stillwell Charles Emmett Phillip Stillwell
EH&S Manager General Manager EH&S Manager
[phone] [phone] [phone]
Compliance Data
! Comments:
Inspection Date 03/13/2018
Inspector's Name Mike Thomas
Inspector's Sig ature: Operating Status Operating
Compliance Code Compliance-inspection
%j Action Code FCE
Date of Signature: On-Site Inspection Result Compliance
Total Actual emissions in TONSIYEAR:
E TSP S02 NOX VOC CO PM10 *HAP
2012 0.0006 --- --- 2.05 -- 0.0006 1329.99
2007 --- --- --- 6.62 --- --- 2941.92
t
I
*Highest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
x
f
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
i
i
f
t
1) Location/Directions
Columbus McKinnon is located at 2020 Country Club Road,just outside of Wadesboro,NC in Anson
County.From the intersection of HWY 74 and HWY 52 in Wadesboro,take Hwy 52 South and go— 1 '/a
i
E
I

3
i
miles to Country Club Road.Turn left and the entrance to building is about 50 yards on right hand side.
Enter through front office.
2) Safety considerations: Standard DAQ safety equipment. Be aware of forklift traffic in the warehouse, as '
well as the heavy hoists that are transferred via overhead conveyor systems to the paint booths.
3) Facility and Process Description
Columbus McKinnon Corp.—Wadesboro Operations is a Division of Columbus McKinnon Corporation.
This facility operates under Air Permit No.3671R10,effective from 20 August 2013 until 31 July 2018.
Mike Thomas conducted the last compliance inspection on 10 January 2017.
The facility produces electric and hand-operated chain and cable hoists,as well as support j
components for hoists. Hoists range in size from 250 pounds to 20 tons lifting capacity. Housing
castings and hoist parts are received from outside vendors, and the hoists are assembled and painted at
this facility. There is a small metal grinding operation for removal of any extraneous metal or burrs
from the metal castings. After full assembly,the hoists are painted in one of three paint spray booths.
The paint booths are equipped with integral panel filters to capture paint overspray droplets.
The painting operations became subject to NESHAP Subpart 6H because the facility utilized coatings
that contained Chromium in excess of 0.1%or Lead in excess of 1%by weight. ]
i
a
Note that the facility has now discontinued the use of coatings with 6H Target HAP. However,the
facility has asked to leave the stipulation in their permit and will continue to comply with the
i
requirements.
4) Emission Sources:
_ err
W........
_.... _.--n.._ ..—�.- _.._ _...
One paint spray booth(filter type)
ES-1375 installed on a metal finishing One spray paint booth
operation CD-1375
(NESHAP) Operating during inspection 0% with panel filters
V.E.observed
....... ... w.. .. ._...
......
One paint spray booth(filter type)
ES-SPR-9 installed on a metal finishing One spray paint booth
(NESHAP) operation Operating during CD-SPR-9 ...with panel filters
inspection 0%V.E.observed.
One paint spray booth(filter type)
ES-SPR-14 installed on a metal finishing One spray paint booth
(NESHAP) operation CD-SPR-14 with panel filters
Operating during inspection 0%
3
V.E.observed.
G
r

t
IE Foam Packaging
Not operating 2Q .0102(c)(2)(E)(i) No I Yes
S-FP
Operating 1 timea weelz. m Q �,.,)( )O('). ..:. .. �.. va n.......
�, . �a .........
operation 2 0102 c 2 E i No Yes
.. __.. __. ...__ ...., _. ..e . . . . __.. . ._._.. � �.,.._. ......
5) Inspection Conference
On 13 March 2018,1 Mike Thomas of FRO DAQ arrived at Columbus McKinnon to conduct a
compliance inspection.I met with the facility contact Phillip Stillwell,EH&S Manager. This was a
planned meeting to discuss the facility's upcoming permit renewal and assist with their emissions
J
inventory. We discussed the following:
a) Verified the FACFINDER;updated to show Mr. Stillwell as the Facility and Technical Contact.
b) I inquired if any of the plant's operations had change. Mr. Stillwell stated that their operations were the
same and their production levels were about the same as last year.
c) We discussed the use of the AERO system for entering the facility's emissions data. Mr. Stillwell said
t
that he felt comfortable using the system but would call me if anything came up.
d) Production:
j Year ES-1375 gallons ES-SPR-14 ES-SPR-9 Total VOCs
gallons gallons
2017 1,104 533 260 0.065
2016 4,400 450 975 0.081
2015 4,410 476 993 0.085
2014 1 4,595 1 494 138 0.083
6) Inspection Summary
Mr. Stillwell led me on a tour of the facility which was operating. I observed the three paint booths
(ES-1375,ES-SPR-9,and ES-SPR-14). All three booths are clearly labeled,according to the permit
Emission Source ID.All three of the booths appeared to be clean and well maintained. Operators
keep a filter log outside of each booth,noting when the filters are changed. I checked each log and all
had current entries.Magnahelics on all three appeared to be functioning properly and were within the
appropriate range compared to logbook readings. I observed no problems with any of the paint
booths.
I
Mr. Stillwell led me to the roof to observe the emission points. I observed 0%V.E. and no indication
of any release of coatings around the emission points.
During the facility tour I observed that VOC work practices are being adhered to. I saw no uncovered
j containers of VOC containing materials,nor did I see any spills or cleaning rags out in the open.
i
7) Permit Stipulations
{ A. A.2 2Q .0304 PERMIT RENEWAL and EMISSIONIIWENTORYREQUIREMENT—
Entire facility subject. Submit permit renewal application and EI at least 90 days prior to
permit expiration.

i
I
3
Appeared to be in compliance—The facility is due to submit their emissions inventory and
3
permit renewal no later than 2 May 2018. I assisted Mr. Stillwell in the use of AERO and he
seemed confident in its use but stated that he would contact me if he needed additional
assistance.He is aware of the submittal deadline.
i
i
B. A.3 21) .0515 PARTICULATES FR OM MISCELLANEO US INDUSTRIAL PROCESSES
i
- i
Particulate matter emissions shall not exceed allowable emission rates
Appeared to be in compliance—Compliance was determined during the most recent permit
review based on operating the source as described in the permit conditions. No changes have
been made to operations since that determination.
C. AA 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENT-Visible emissions
from the emission sources manufactured after July 1, 1971, shall not be more than 20%
opacity.
Appeared to be in compliance-I observed 0%VE from all sources during my inspection. I
also saw no indication of coatings being emitted through the roof emission points during the
inspection tour.
D. A.5 2D .0535 NOTIFICATION REQUIREMENT- The facility is required to notify DAQ
if excess emissions occur for more than a 4-hour period caused by a breakdown or other
abnormal condition.
Appears to be in compliance—Mr. Stillwell stated that he was unaware of any exceedances,
breakdowns,or abnormal conditions that would require notification.
E. A.6 2D .0540 FUGITIVE DUST CONTROL REQUIRMENT—The Permittee shall not
cause or allow fugitive dust emissions to contribute to complaints or excessive visible
emissions beyond the property boundary.
Appeared to be in compliance—I observed no fugitive dust emissions. This facility has all
paved roads and parking.FRO DAQ has received no complaints against the facility. Mr.
Stillwell stated that he was unaware of any complaints being received by the facility.
F. A.7 2D .0958(c) WORKPRACTICES REQUIREMENTS—The Permittee shall employ
good manufacturing practices to prevent the evaporation of VOC containing materials.
Appeared to be in compliance-I found.the facility's handling, cleaning and storage of all
their paints, solvents and thinners compliant with the requirements of this rule.All VOC-
materials were in covered containers,I observed no spills, and I observed no spent rags in
open containers.The facility conducts annual staff training regarding VOCs as well as
training for new hires.
G. A.8 21) .1111 MAXIMUMACHIEVABLE CONTROL TECHNOLOGY—Applicability of
GACT Subpart HHHHHH"Paint Stripping and Miscellaneous Surface Coating Operations at
Area Sources"—Facility must use High Volume Low Pressure(HVLP)spray heads for
painting,paint booth filters must provide at least 98%capture efficiency,maintain records of
training and certifications for each employee conducting paint spraying operations.
Appeared to be in compliance—The facility maintains the three spray paint booths in
compliance with 6H requirements including HVLP spray guns. Records are kept for each
employee that operates a spray booth documenting their training history. Records
documenting the filter efficiency(98%)and frequency of maintenance for each spray booth.
The facility continues to adhere to the requirements of 6H even though the paints in use do
not contain the subject chemicals.

H. A.9 2Q .0711 TOXICAIR POLL UTANTEMISSIONLIMITATION REQUIREMENT—
The Permittee shall maintain records of operational information demonstrating that the TAP
emissions do not exceed the TPER listed as MIBK 52 lbs/day, Toluene 98 lbs/day, and
Xylene 571bs/day.
Appeared to be in compliance—The facility is well below the TPERs for MIBK 0.009
lbs/day, Toluene 0.65 lbs/day, and Xylene 7.93 Ibs/day.
I. A.10 2Q .0803 COATING,SOLVENT CLEANING AND GRAPHICARTS
EXCLUSIONARYRULE REQUIREMENTS-The facility potential emissions shall be less
than 100 tons per year VOC, 10 tons per year each HAP, and 25 tons per year all HAPs. The
Permittee shall maintain records and submit an annual report of facility emissions.
Appeared to be in compliance—The facilities emissions are well below the limits set forth
above. 2.1 tons of VOC, 1.03 tons of Xylene, and 1.23 tons total for HAPs. The facility's
latest annual report was received on time and was compliant.
8) 112R Status
This facility does not store chemical compounds that require a written risk management plan under
the Clean Air Act, Section 112R.
9) Non-compliance History Since 2010
None.
10) Comments and Compliance Statement
Columbus McKinnon Corp.—Wadesboro Operations appeared to be in compliance with the
conditions in their current air permit on 13 March 2018.
PINK SHEET: Recommend removing the 2D .0958 stip during upcoming permit renewal since the
recent legislative change makes it applicable only in non-attainment and maintenance areas and this
county is in attainment:
Inquire how the facility complies with 2Q .0711. Is it daily average,worse-case scenario etc.?
E
/mst
i
k
f
i
I
i
i
I
E
f
t
E
t

1
1
i
i
i
i
N
I�
��
�,
i