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HomeMy WebLinkAboutAQ_F_0400030_20170110_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: 022/2017 Facility Data Permit Data Columbus McKinnon Corp-Wadesboro Operations Permit 03671/Rl0 2020 Country Club Road Issued 8202013 Wadesboro,NC 28170 Expires 7/312018 Lat: 34d 56.5990m Long: 80d 3.1730m Classification Small SIC: 3536/Hoists,Cranes,And Monorails Permit Status Active NAICS: 333923/Overhead Traveling Crane,Hoist,and Monorail System Current Permit Application(s)None Manufacturing Program Applicability Contact Data Facility Contact Authorized Contact Technical Con[ac[ SIP MACT Part 63: Subpart 6H Donald Sears Charles Emmett Donald Sears EHS Coordinator General Manager EHS Coordinator (704)994-6377 (704)694-2156 (704)994-6377 Compliance Data Comments: Inspection Date 01/102017 Inspector's Name Mike Thomas I nspect natur Operating Status Cod Operating Compliance Code Compliance-inspection Action Code FCE gnature: On-Site Inspection Result Compliance Z 2— Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PMIO *HAP 2012 0.0006 --- -- 2.05 -- 0.0006 1329.99 2007 --- --- -- 6.62 -- --- 2941.92 *Highest HAP Emitted inponds) Five Year Violation Historv:None Date Letter Type Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Sourcefs)Tested 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— I Y/ miles to Country Club Road.Tom left and 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 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 18 November 2015. The facility produces electric and hand-operated chain and cable hoists,as well as support 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. Note that the facility has now discontinued the use of coatings with 6H Target HAP. However,the Subpart 6H requirements still apply to the facility because the facility has not requested an exemption from the regulation for not using the target HAP. The facility has not made the request to be exempt due to their desire to remain subject to the requirements set forth in 6H. 4) Emission Sources: Emission Emission Source Control Control System Source 1D Description System m Description One pain[spray booth(filter type) installed on a metal finishing ES-1375 One spray pain[booth operation CD-1375 (NE511AP) Operating during inspection 0% with panel filters V.E.observed. One P rati spray booth(filter g e) p a p ES-SPR-9 installed on a metal finishin One s ra amt booth (NESHAP) operation Operating during i CD-SPR-9 with panel filters ius ection 0%V.E.observed. One paint spray booth(filter type) ES-SPR-14 installed on a metal finishing (NE51iAP) operation CD-SPR-14 One spray paint booth Operating during inspection 0% with panel filters V.E.observed. Source I Exemption Regulation Source of Source of Title V TAPS? Pollutants? IES-FP-Foam Packaging .Not operating 2Q.0102(c)(2)(E)(i) No Yes ;IES-937-metal grinding operation Operating 1 time a week 2Q.0102(cx2)(E)(i) No Yes 5) Inspection Conference On 10 January 2017,I Mike Thomas of FRO DAQ arrived at Columbus McKinnon to conduct a routine compliance inspection.I met with the facility contact Donald Sears. We discussed the following: a) Verified the FACFINDER; no changes are necessary. b) I inquired if any of the plant's operations had change. Mr. Sears stated that their operations were the same and their production levels were about the same as last year. ES-1375 ES-SPR-14 I ES-SPR-9 Total VOCs 2016 4,400 gal 1 450 gal 1 975 gal 0.08E 2015 4,410 gal 476 gal 1 993 gal 0.085 2014 4,595 gal 494 gal 1 138 gal 0.083 6) Inspection Summary Mr. Sears 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 active 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. I observed no problems with any of the paint booths. During the facility tour I observed that VOC work practices are being adhered to. I saw no uncovered containers of VOC containing materials,nor did I see any spills or cleaning rags out in the open. 7) Permit Stipulations a) A.22Q.0304 PERMITRENEWAL and EMISSIONLNrVENTORYREQUIREMENT—Entire facility subject. Submit permit renewal application and El at least 90 days prior to permit expiration. Appeared to be in compliance—The most recent El and Permit Renewal were due on 2 July 2013. The facility submitted their El and permit renewal application on 27 June 2013. b) A.3 2D.0515 PARTICULATES FR OM MISCELLANEO US INDUSTRIAL PROCESSES- 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) A.4 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. 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. Sears stated that she 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. 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. Sears stated that she was unaware of any complaints being received by the facility. f) A.7 2D.0958(c) WORK PRACTICES 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 V OCs as well as training for new hires. g) A.8 2D.l 111 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 remains subject to and 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 TOXIC AIR POLLUTANT EMISSION LLIHTATIONREQUIREMENT—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 57 lbs/day. Appeared to be in compliance—The facility is well below the TPERs for MIBK 0.006 lbs/day, Toluene 0 lbs/day,and Xylene 0.011 lbs/day. i) A.10 2Q .0803 COATING,SOLVENT CLEANING AND GRAPHIC ARTS EXCLUSIONARY RULE 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. 0.085 tons of VOC,4 lbs of Xylene,and 7 lbs 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 appeared to be in compliance with the conditions stipulated in their current air permit on 10 January 2017. 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. /mst