AQ_F_0400030_20151118_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: 12/08/2015
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
NAICS: 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
Donald Sears Charles Emmett Donald Sears
EHS Coordinator General Manager EHS Coordinator
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 11/18/2015
Inspector's Name Mike Thomas
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
.4 Action Code FCE
Date of Signature: On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *11"
2012 0.0006 --- 2.05 0.0006 1329.99
2007 6.62 --- 2941.92
*Highest HAP Emitted in pounds)
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) 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 1/2

miles to Country Club Road. Turn left and entrance to building is about 50 yards on right hand side.Enter j
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 26 February 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:
One paint spray booth(filter type)
F installed on a metal finishing
ES-1375 Ones spray paint booth
operation CD-1375 p(NESHAP) with panel filters
Operating during inspection 0% �
V.E.observed.
i One paint spray booth(filter type)
ES-SPR-9 installed on a metal finishing CD-SPR 9 One spray paint booth
(NESHAP) operation Operating during I with panel filters
inspection 0%V.E.observed.
i
One paint spray booth(filter type)
i ES-SPR-14 Installed on a metal finishing
operation One spray paint booth j
(NESHAP) Operating during inspection 0% CD-SPR-14 with panel filters
V.E.observed.
I

Insi nificant Sources:
IES-FP-Foam Packaging 2Q.0102(c)(2)(E)(i) No Yes
Not operating
IES-937 -metal grinding operation 2Q.0102(c)(2)(E)(i) No Yes
;Operating 1 time a week.
5) Inspection Conference
On 18 November 2015,I Mike Thomas of FRO DAQ arrived at Columbus McKinnon to conduct a
routine compliance inspection. I was informed that the facility contact David Sears was not onsite due
to taking an employee to be treated for an injury. I met briefly with Ms.Deborah Taylor, Mr. Sear's
assistant. I spoke to Mr. Sears on 30 November 2015 to discuss production numbers and having the
facility be exempted from 6H. Mr. Sears stated that he would pose the question of filing the
paperwork to be exempt from 6H to his superiors again to see if their position has changed.
Throughputs for 2015
Employees: 225 (225 in 2014)
Hours: V shift 6:30AM—2:30PM, 52 weeks/year
nd _
ES-137 ES-SPR-14 ES-SPR-9 Total VOCs
2015 4,410 gal 476 gal 993 al 0.085
2014 4,595 al 494 gal 138 gal 0.083
* Based on reviewing the facility's Annual HAP &VOC report it was discovered that there were
numerous errors in the spreadsheet used to calculate these values. The numbers were grossly
incorrect and inflated in the past. This error was corrected and appropriate numbers submitted in the
Facility's 2016 Annual Report.
6) Inspection Summary
Ms. Taylor led me on a brief 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. I observed that the areas immediately outside of the booths were
clean, and all of the handling,cleaning and storage areas near the booths were clean as well.
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.2 2Q .0304 PERMIT RENEWAL and EMISSIONINVENTORYREQUIREMENT-Entire
facility subject. Submit permit renewal application and EI at least 90 days prior to permit
expiration.
Appeared to be in compliance—The most recent EI and Permit Renewal were due on 2 July
2013. The facility submitted their EI and permit renewal application on 27 June 2013.
b) A.3 2D .0515 PARTICULATES FROM MISCELLANEOUS 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—Ms. Taylor 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. Ms. Taylor
stated that she 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 MAXIMUMA CHIE VABLE 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 TOXICAIRPOLLUTANTEMISSIONLIMITATIONREQUIREMENT—The
Permittee shall maintain records of operational information demonstrating that the TAP emissions
do not exceed the TPER listed as MIBK 521bs/day, Toluene 981bs/day, and Xylene 57 lbs/day.
Appeared to be in Compliance—The facility is well below the TEPERs 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 GRAPHICARTS 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 annual report
was due by 31 March 2015. It was received on 17 February 2015 and was compliant.
8) 112R Status
This facility neither uses nor stores chemical compounds that require a written risk management plan
under the Clean Air Act, Section I I2R.
9) Non-compliance History Since 2010
None.
10) Comments and Compliance Statement
Columbus McKinnon appeared to be in compliance on 18 November 2015.
PINK SHEET: N/A
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