AQ_F_0900049_20151119_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
( AIR QUALITY 8 Taylor Mfg t
NC Facility ID 0900049 )
Inspection Report CountylFIPS:Bladenl017
t Date: 12/11/2015
Facility Data Permit Data
1 t
Taylor Mfg Permit 069631 R04
1585 US 701 South ® Issued 5116/2011
Elizabethtown NC 28337 Expires 4/30/2016
: Lat:34d 36.7370m Long: 78d 36.8200m t Classification Small
s SIC: 3559 t Special Industry Machinery Nee Permit Status Active 1
NAICS: 333111 1 Farm Machinery and Equipment Manufacturing Current Permit Application(s)None I
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Charles King Denise Bridgers Denise Bridgers )
Plant Supervisor Secretary Treasurer Secretary Treasurer
i [phone] [phone] [phone] t
Compliance Data 1
Comments: i
Inspection Date 11/19/2015
Inspector's Name Pam Vivian
Inspector's nature: Operating Operating
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Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: IZ a H; On-Site Inspection Result Compliance
Total Actual emissions in TONSIYEAR:
TSP S02 NOX VOC CO PMIO CHAP t
2009 -- 6.17 --- --- 905.00
2004 -- --- _— 15.00 --- --- 311100
i Hi est HAP Emitted(in pounds)
Five Year Violation History:None i
9 Date Letter Type Rule Violated Violation Resolution Date a
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Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Sourcets)Tested
1)Directions:
From FRO take highway 87 south and travel about 35 miles toward Elizabethtown. On the Hwy 87 south
bypass,turn left at the stoplight onto US 701. Travel about 1.5 miles and the facility is on the right.

2) Standard DAO FRO Safety gear:
Glasses are required in all areas,whereas ear-plugs and bard 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)Facilillyrocess 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)Eauipment List:
Permitted Sources:
RUN
K � r T
ESl Paint spray booth with 96 square feet of filter area Not operated Fitters goad
during inspection
Paint spray booth with 96 square feet of filter area
ES2 ;Observed with recently painted form drying;Filters good
Operated earlier
Operating at—0.5 gallons paintlhr; A
ES3 Paint spray booth with 96 square feet of filter area
Operated earlier ,! Observed with recently painted form drying; Filters good
Operating at—0.5 gallons paintlhr;
ES4 NIA
Paint spray boot with 156 square feet of filter area
3
` Not operated 1 )Filters good
during inspection.
t Paint spray boot with 156 square feet of filter area j
i Not operated
.duringinspection. :
Filters good
Paint spray boot with 156 square feet of filter area
ES6 Observed workers constructing form with pre mfg
Operating. insulation sheets. No insulation spraying being done. j I
Filters good
5) Inspection Summary
a)On 19 November 2015, I, Pam Vivian of DAQ FRO met with Mr. Charles King,Plant Supervisor, for
a compliance inspection and offer any emission inventory assistance. Ms.Bridgers met with me and
stated she would do the inventory and submit it through AFRO. I provided to her a copy of her reminder
letter and discussed accessing AFRO. I told her she would need to submit the inventory by 31 January
2016 with supporting calculation and current MSD sheets indicating chemical content. I told her if She
had any questions to call me. Ms:Bridgers left for another appointment.
b)Mr.King reviewed the FACFINDER. He provided me with a copy of the current permit. I asked if the
facility had changed anything since the last inspection. He said they were 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. The facility still has not
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used any MEK or styrene in their manufacturing process since 2008. I reminded Mr. King the annual
report for stipulation A9 was due by I March 2016 for calendar year 2015. He made a note and placed it
on Ms.Bridger's desk. He guided us on the inspection.
c)At the metal;fabrication building, I observed 3 employees at two different work stations. Two were
cutting a large metal sheet and one was spot welding. Mr. King said less welding is done with the new
designs the engineers had developed over the past year.
d)At the assembly building, I observed 8 employees assembling heaters and other metal framed units.
Mr.King showed me how the new design features involved less welding and now incorporate rivets and
i metal screws that when installed along with the pre-fab insulation sheets,create a better and efficient
product for the customer. He told me the facility is keeping up with the latest EPA requirements so they
too can increase sales.
3 e)At the finishing building,I observed the five spray booths and 611 booth where pre-fab insulation
sheets, and if used, insulating foam spray, are applied to the units. Each booth is IS' by 8' and have
fabric filters'with negative pressure fans for outside exhaust. Booths ES-2 and ES-3 had been operated
earlier that morning and had stove units air drying. Mr.King said the filters are changed about every
three months and the new overhead clamp bars keep these filters in place. He noted the 2014 deviation
letter from the inspection where two booths had filters that were compromised on the right upper edges,
showing signs of leaks. He said their engineers developed a clamp system to properly hold the filters in
place during;operation. He said there is not enough business to simultaneously operate all six spray
booths so the facility chooses different booths to apply the needed paints. All paint containers were
closed in both booths. Mr. King said it generally takes about four days from start to finish for a unit to
receive the proper coatings:
€ THROUGHPUTS:
Number of Em 7o ees 16
Hours of Operation Mon—Thurs; 7:00 am to 3:30 Pm;office on Fri
Paint/Solvents Usage 2015—7000 gals;2014 -—6325:2013-—5500;
2012——5100;2011 —4700
6)Permit Stigulafions:
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—This facility's next El is due 31 January 2016 with the permit
expiring 30 April 2016. Mr.King stated that Ms. Bridgers would be submitting the El through AERO. If
need she would call this office.
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 changes 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 asix-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"Facility is required to notify the DAQ of excess emissions
that last for more than four hours_
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 are paved,except for a dirt/gravel
customer parking lot. The facility grounds were wet due to the current rainfall. Mr. King stated no
complaints have been received at the facility.
A.7 2D.0958(e)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 he reminds the employees of these work practice and uses this
specific page of requirements to keep his employees aware. 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 are not used in manufacturing processes. Mr.
King provided documentation of the chemical usage and time required to manufacture products
containing toluene and xylene. Both TAPs are well below the permitted emission rates.
A.9 2Q.0803 EXCLUSIONARY RULE REQUIREMENTS-The Permiuce 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 2014 was received 27 February 2015 and
reported:Total VOCs—32,923 Ibs;Greatest HAPs(toluene)—2852 Ibs;and Total HAPs 3570 lbs. i
7)Non-Compliance History since 2010:
O 14 February 2014 NOD: Failure to Operate and Maintain.spray booth filters in ES-2 and ES-3. On i
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 in compliance with its current air permit.
Pink Sheet Comments:
None i
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