AQ_F_0900049_20161209_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Taylor Mfg
NC Facility ID 0900049
Inspection Report County/FIPS: Bladen/017
Date: 01/04/2017
Facility Data Permit Data
Taylor Mfg Permit 06963/R05
1585 US 701 South Issued 3/14/2016
Elizabethtown,NC 28337 Expires 2/29/2024
Lat. 34d 36.7370m Long: 78d 36.8200m Classification Small
SIC: 3559/Special Industry Machinery Nec Permit Status Active
NAICS: 333111 /Farm Machinery and Equipment Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Charles King Denise Bridgers Denise Bridgers
Plant Supervisor Secretary Treasurer Secretary Treasurer
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 12/09/2016
./ Inspector's Name Pam Vivian
Inspector's Signature: 4"�µt U/ a Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: 1/4//7 y'I,( On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR: �i
TSP S02 NOX VOC CO PM10 *HAP
2014 16.47 --- 2728.11
2009 --- --- 6.17 --- --- 905.00
* Highest HAP Emitted in ounds)
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
1)Directions:
From FRO take highway 87 south toward Elizabethtown;turn left at the stoplight onto US 701; facility is
on the right.

2) Standard DAQ FRO Safety gear:
Glasses are required in all areas,whereas ear-plugs and hard hat only in fabrication and assembly areas
when machinery is operating. Be alert to fork-lifts and golf carts moving around while on facility
grounds.
3)Facility/Process Description:
Taylor Manufacturing builds farm equipment, small metal storage buildings, ice houses, and wood/coal
burning water heaters. Taylor receives sheet metal and structural tubing. There are different buildings for
the fabrication,assembly/welding, and finishing of the products. The permitted emission sources are six
spray booths each about 8 ft by 15 ft, large enough to accommodate products. These booths are used for
the painting of the product and the application of the insulating foam. Facility is phasing out insulating
foam and purchasing large pre-manufactured insulation sheets.
4)Equipment List:
Permitted Sources:
Emission i Emission Sourc System
l
Source ID Description
. : ascription`
Paint spray booth with integral panel filters (�
ESI �� 96 square feet of filter area N/A N/A
Not Operating; filters appeared compliant i FPaint spray booth with integral panel filters
ES2 96 square feet of filter area N/A N/A
Not Operating; filters appeared compliant
Paint spray booth with integral panel filters
ES3 96 square feet of filter area FN/A N/A
Not Operating; filters appeared compliant
Paint spray booth with integral panel filters
ES4 156 square feet of filter area FN/A N/A
Not Operating; filters appeared compliant
Paint spray booth with integral panel filters
ES5 156 square feet of filter area N/A N/A
�F Not Operating; filters appeared compliant
Paint spray booth with integral panel filters
ES6 156 square feet of Filter area N/A N/A
Not Operating; filters-appeared compliant
5)Inspection Summary
On 9 December 2016,I,Pam Vivian of DAQ FRO arrived at the facility. I did not detect any chemical
odors or observed any indications of fugitive emissions. Ms. Bridgers was there and spoke with me for a
few minutes. I inquired if Charles King or herself had reviewed and discussed the June 17,2016 email
sent out by FRO DAQ explaining about permit exemption or reclassification, and included several
attachments concerning it for this facility. She said she did not remember such an email so I told her to
look into past emails. I noted this same email had been forwarded to all facilities again in August 2016 to
further remind each to review and if there were any questions to call Greg Reeves who would address any
concerns. I also reminded her that the annual report would be due by 1 March 2017 to satisfy the
requirements of stipulation 9 in the air permit. Ms.Bridgers said she needed to attend a meeting and
requested that Mr.Ethan King,Acting Plant Supervisor while Charles King was on leave,to guide me
during this compliance inspection. Before leaving she reviewed the FACFINDER and said they employ

16 workers and still manufactured Monday through Thursday from lam to 3:30pm and the office
operated only on Friday. She then handed Mr. King a copy of the air permit,a year-to-date spreadsheet
for the chemical usage containing VOC, HAPs, and Total HAPs, and documentation of the chemical
usage and time required to manufacture products containing toluene and xylene.
After Ms. Bridgers left, I reviewed the records provided and asked Mr.King about MEK and styrene
being used during manufacturing. He said they still do not use any MEK or styrene in the manufacturing
process. Review of the records appeared acceptable. I asked if the facility had changed anything since
the last inspection. He said there have been no changes and noted they still continue buying pre-
manufactured insulation sheets to use in the stoves and ice machines. He said the facility is working
towards less emissions throughout the manufacturing processes of each item that's produced. He guided
me on this inspection.
At the metal fabrication building, I observed 5 employees at three different work stations. Two were
cutting and one was shaping large metal sheets. Two were fine grinding a large metal sheet. I did not
observe anyone welding. Mr. King said the better designs the engineers had developed over the years,
requires less welding.
At the assembly building, I observed 8 employees building heaters and other metal framed units. I did not
observe as many assembled units as compared during the previous inspection. Mr.King showed me how
the new design features involved less welding, incorporated rivets,and metal screws that when installed
along with the pre-fab insulation sheets, create a better and more efficient product for the customer. He
told me Ms.Bridgers continue to keep up with the latest EPA requirements for the heater units to
hopefully increase sales to other states where rules have and are changing for emission reasons.
At the finishing building,I did not observe any personnel there as we walked through. I went to each of
the six spray booths to observe the integral panel filters and each filter was properly installed and
attached. He said the metal holding clamp rod developed by the engineers has made a difference in
keeping the filters in place without slipping as had been experienced in the past. The filters are changed
about every three months. Booths 1 through 3 were empty of any products. Booths 4 through 6 had
products in each that had been sprayed with a rusty red in booth 4,black in booth 5,and white insulation
foam in booth 6 but were drying from having been sprayed earlier that morning. He said the workers
switch to different booths to apply the various chemical needed on the specific product since there is not
enough business to simultaneously operate all six spray booths. He did say that booth 6 is always used to
apply the white insulation foam. I did not observe any open chemical containers nor did I detect any
strong odors.
THROUGHPUTS:
Year VOC,TPY Total HAPs,TPY Lg HAPs,TPY HAP type
2016 as of inspect 12.1 2.3 1.2 X lene
2015 13.3 3.0 1.6 X lene
2014 16.5 1.8 1.4 Toulene
6)Permit Stipulations:
A.2 2D.0202—"Permit Renewal and Emission Inventory Requirement"—At least 90 days prior to
the expiration date of this permit,the Permittee shall submit the permit renewal application and air
pollution emission inventory.
APPEARED IN COMPLIANCE—The permit renewal package was due by 31 January 2016 and was
received on 21 January 2016. Next permit renewal will be due in November 2023.

A.3 2D .0515 PARTICULATE CONTROL REQUIREMENT— Particulate matter emissions from
the emission sources shall not exceed allowable emission rates.
APPEARED IN COMPLIANCE—The last permit review indicated compliance based on the sources
being operated as permitted. There have been no operational changes made to each source since the last
review.
AA 2D.0521 VISIBLE EMISSIONS CONTROL REQUIREMENT—Visible emissions from the
emission sources manufactured after July 1, 1971, shall not be more than 20 percent opacity when
averaged over a six-minute period.
APPEARED IN COMPLIANCE—No emission sources were being operated at the time of inspection.
I did not observe any accumulation of emissions at exhaust points.
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.
APPERARED IN COMPLIANCE—Mr. King stated there have been no occurrences of excessive
emissions since the last inspection.
A.6 2D. .0540 "PARTICULATES FROM FUGITIVE DUST EMISSION 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.
APPEARED IN COMPLIANCE -I did not observe any accumulated dust emissions on the surrounding
property or at the entrance/exit access roads. The facility grounds arc paved,except for a dirt/gravel
customer parking lot. Mr. King stated no complaints have been received at the facility.
A.7 2D.0958(c)WORK PRACTICES REQUIREMENTS—Careful handling, storage and clean-up of
solvents.
APPEARED IN COMPLIANCE—I observed no uncovered containers of paint or other solvents during
this inspection. Covered waste containers are at various locations where manufacturing needs require
disposal of such materials. Mr.King said employees arc reminded of these work practice and he refers to
this specific page of requirements for compliance awareness. All containers in the storage room were
covered as well.
A.8 20.0711 TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT-The
Permittee shall limit the emissions of all TAPS, including styrene,toluene,MEK,and xylene to less than
the TPER limit.
APPEARED IN COMPLIANCE—Styrene and MEK arc not used in manufacturing processes. It is
preferred by Ms. Bridgers to keep both these chemicals on the permit for possible future needs. Mr. King
provided documentation of the chemical usage and time required to manufacture products containing
toluene and xylene. Both HAPs are well below the permitted emission rates.
A.9 20 .0803 EXCLUSIONARY RULE REQUIREMENTS-The Permittee shall limit total VOCs,
greatest HAP, and total HAPs emissions, respectively to less than 100/10/25 TPY and submit an annual
report by 1 March for the previous year's emissions.
APPEARED IN COMPLIANCE—The annual report for CY 2015 was received 26 February 2016 and
reported: Total VOCs—26,551 lbs; Greatest HAPs(xylene)—3,107 lbs; and Total HAPs—5956 lbs.
7)Non-Compliance History since 2010:
• 14 February 2014 NOD: Failure to Operate and Maintain spray booth filters in ES-2 and ES-3. On
27 February 2014 a response was received stating corrective actions implemented at each spray
booth to prevent filter failures.

8) 112r Status:
This facility does not use or store any chemicals that require a written Risk Management Program under
40 CFR Part 68.
9) Comments/Compliance Statement:
Taylor Manufacturing has steadily reduced its emissions by changing chemical content,developing new
designs for production, and recently incorporating pre-fabricated insulation sheets into some of its
products. The facility appeared to be operating in compliance with its current air permit at the time of this
inspection.
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.
/pcv