AQ_F_0900049_20140206_CMPL_InspRpt

— NORTH CAROLINA DIVISION OF Fayetteville Regional Office
— AIR QUALITY Taylor Mfg
NC Facility ID 0900049
Inspection Report County/FIPS:Bladen/017
Date: 02/14/2014
Facility Data Permit Data
Taylor Mfg Permit 06963/R04
1585 US 701 South Issued 5/16/2011
Elizabethtown,NC 28337 Expires 4/30/2016
Lat: 34d 36.7370m Long: 78d 36.8200m Classification Small
SIC: 3559/Special Industry Machinery Nee 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 SII'
Denise Bridgers Denise Bridgers Charles King
Secretary Treasurer Secretary Treasurer Supervisor
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 02/06/2014
Inspector's Name Neil Joyner
Inspector's Signature: �1 H Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: l) � � On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2009 --- 6.17 --- --- 905.00
2004 15.00 --- --- 3112.00
*Highest HAP Emitted(in pounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
MACT/GACT:
GACT 6H: According to their MSDS,the paint and thinner used in the six permitted spray booths does
not include any 6H subject HAP metals.

-- GACT 6X: The facility performs metal fabrication, including laser cutting and welding, but they are not
-- subject to GACT 6X because their NAICS and SIC numbers are not on the EPA listing of subject
facilities.
GACT 4Z and 6J: The facility has no emergency generator or boiler.
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.
Safety Considerations:
All standard FRO safety gear is required. Be aware of moving forklifts and golf carts.
Facility Description:
Taylor Manufacturing builds farm equipment, small metal storage buildings,and wood/coal burning
stoves,utilizing sheet metal and structural tubing. There are three buildings at the site: (1)metal
fabrication including laser cutting and welding, (2)spray painting, and(3)assembly and finishing. The
permitted emission sources are six paint spray booths. No insignificant sources are listed on the current
permit.
Number of Employees 3 in the paint shop
Hours of Operation Mon-Thurs; 7:00 am to 3:30 m; office on Fri
Production -40 units of various sizes produced in CY2013;
Purchased 1155 gallons ofpaint/thinner in CY2012
Emission Sources and O eratin Status:
-
Paint spray booth with 96 square feet of filter area
ES 1 Operating at 0 5 gallons paint/hr;-0%opacity. I j
-ES2 Paint spray booth with e
th square feet of filter area
_
g.
Paint spray booth with 96 square feet of filter area
E S 3 j Not operating. N/A
ES4 Paint spray boot with 156 square feet of filter area
=Not operating.---- _--
ES5 Paint spray boot with 156 square feet of filter area
-Not operating.
Paint spray boot with 156 square feet of filter area
ES6 Operating at-0.5 gallons paint/hr 0%opacity.
Inspection Summary:
On 6 February 2014,I;Neil Joyner of DAQ FRO,met with Denise Bridgers,Authorized Contact, and
Charles King,Facility Contact,to conduct a compliance inspection. Mr. King stated that the FAC
FINDER was up to date. He stated that there had been no changes to the facility equipment or process
since the last inspection. He stated that he had received no complaints from anyone regarding air quality.
He stated that his current permit equipment listing appeared correct. Ms.Bridgers stated that a while
back,Pam Vivian and another person from my office investigated a complaint regarding smoke from a
woodstove on the site. She stated that the complaint was resolved when adjustments to this woodstove

-- were made. She stated that her air permit was back in the file room right now. After I had left that day,
-- Ms.Bridgers emailed me a scanned copy of the cover page of her current air permit.
During my walk-through,I observed a steam plume from the stack of a small woodstove on the north side
of the building. No visible smoke was observed detaching after the steam had dissipated. I also observed
blue smoke emissions,from the stack of a small woodstove on the east side of the building,that were
—15%opacity. Mr.King stated that these woodstoves were being used to provide heat for the buildings.
I observed an unconnected smoke stack at the site that Mr.King stated had been used in the past to test
woodstoves made by the facility. I observed no other visible emissions while at the site that day. I
observed no objectionable odor downwind just off the facility boundary. I observed that the metal
fabrication building included a laser cutter with associated bagfilter that vented to the inside of the
building.
During my walk-through of the paint spray booth building, I observed that the fabric filter for permitted
paint spray booth ES 1 was not completely covering the air outlet, apparently allowing unfiltered air from
the booth to be released outside during operation. Mr.King stated that he agreed that this was a problem
and that he would make repairs. Mr.King also stated that this booth(ES-1)was in operation earlier that
day at the time I had checked in at the front desk. I also observed that the fabric filter in permitted booth
ES2 was not completely covering the outlet although this booth was not operating at the time. I went
outside behind this building and did not observe any visible emissions from any of the paint booth stacks.
I also did not observe any paint deposits on the side of the building or on the adjacent vegetation in the
wood line.
Reeulatory Review:
A.3 2D .0515 PARTICULATE CONTROL REQUIREMENT—Particulate matter emissions from
the emission sources shall not exceed calculated allowable emission rates.
Appeared in Compliance—Compliance was determined by the permit writer,based on operating these
sources as in the permit application. There have been no changes to these sources.
A.4 2D .0521 VISIBLE EMISSIONS CONTROL REOUIREMENT—Visible emissions from the
emission sources,manufactured after July 1, 1971, shall not be more than 20% opacity when averaged
over two six-minute periods.
Appeared in Compliance—No visible emissions above 20% opacity were observed during this
inspection. A woodstove was observed operating at—15%opacity and another was observed with a
steam plume with no visible smoke detachment.
A.6 2D. .0540 PARTICULATES FROM FUGITIVE DUST EMISSION SOURCES—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—No fugitive dust emissions were observed beyond the facility boundaries.
A.7 2D .0958 "WORK PRACTICES FOR SOURCES OF VOLITILE ORGANIC COMPOUNDS -
Store all VOC-containing material not in use (including waste material) in containers covered with a
tightly fitting lid that is free of cracks, holes, or other defects. Clean up spills as soon as possible
following proper safety procedures. Store wipe rags in closed containers.
Appeared In Compliance — All VOC-containing materials not in use were being stored in covered
containers with tightly fitting lids. No spills of VOC-containing materials were observed. Wipe rags
were being stored in closed containers when not in use.

--- A.8 20 .0711 TOXIC AIR POLLUTANT ENIISSIONS LINHTATION REOUIREMENT -The
Permittee shall operate and maintain the facility such that the emissions of TAPS, including styrene,
toluene,MEK, and xylene, shall not exceed their TPERs.
Appeared in Compliance-Processes have not changed since last permit review. Permitted TPER's
styrene and MEK were no longer being used at the facility. Permitted TPER's toluene and xylene were
still being used. Based on the facility's CY2012 usage of paint and thinner and times of operation,
TPER's for toluene and xylene did not appear to have been exceeded. The material usage for CY2013
had not been compiled yet because their CY2013 annual report was not due until 1 March 2014.
A.9 20 .0803 EXCLUSIONARY RULE REOUIPEMENTS -The Permittee shall limit VOC
emissions to less than 100 tpy,the largest HAP emission to less than 10 tpy, and the total HAP emission
to less than 25 tpy; submit annual report for the previous year's emissions to this office by March 1 of the
following year.
Appeared in Compliance-The annual report for CY 2012 was received 1 March 2013 and reported
usage as: Total VOCs-6506 lbs; Greatest HAPs(toluene)-547 lbs;and Total HAPs-696 lbs. The
facility's spreadsheet,being used to compute these emissions,was based on material purchases and
MSDS listings. These computations appeared to agree with the submitted CY2012 annual report.
B.6 GENERAL CONDITION-The facility shall be properly operated and maintained at all times in a
manner that will effect an overall reduction in air pollution.
Appeared in Compliance(Concern Expressed)-During my walk-through of the paint spray booth
building, I observed that the fabric filter for permitted paint spray booth ES 1 was not completely covering
the air outlet, apparently allowing unfiltered air from the booth to be released outside during operation.
Mr.King stated that he agreed that this was a problem and that he would make repairs. Mr.King also
stated that this booth(ES-1)was in operation earlier that day at the time I had checked in at the front
desk. I also observed that the fabric filter in permitted booth ES2 was not completely covering the outlet
although this booth was not operating at the time.
-- 112r Status:
The facility does not use or store applicable materials in quantities requiring a written risk management
plan.
Compliance History:
There have not been any non-compliant issues at this facility over the last 5 years.
Recommendations and Compliance Statement:
Based on review of records and visual observations, this facility appeared to be operating in compliance
with their air quality standards and regulations at the time of this inspection except for the concern noted
above regarding the filters in the paint spray booths.
Recommend B6 NOD: Fabric filter for permitted paint spray booth ES was not completely covering the
air outlet,apparently allowing unfiltered air from the booth to be released outside during operation.
/caj