AQ_F_0400030_20140311_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: 03/19/2014
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 Lang: 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
FacilityContact Authorized Contact Technical Contact SIP
MACT Part 63: Subpart 6H
Rena'Hart Joseph Ombrello Rena'Hart
EHS Coordinator General Manager EHS Coordinator
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 03/11/2014
Inspector's Name Mike Thomas
Inspector's Si nature: Operating Status Operating
0 Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: ( On-Site Inspection Result Compliance
Total Actual emissions in TONSIYEAR:
TSP SO2 NOX VOC CO PMIO * HAP
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
Columbus McKinnon is located at 2020 Country Club Road,just outside of Wadesboro,NC in Anson
County.
Directions
_ From FRO,take Hwy 401 South to Wagram. Turn right at Old Wire Road(Hwy 144)and go— 11 %z miles
to Laurel Hill. Turn right at Hwy 74 and go west—35 miles to Wadesboro.Turn left onto Hwy 52 South
and go— 1 %miles to Country Club Road. Turn left and entrance to building is about 50 yards on right
hand side. Enter through front office.
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.
2) Facility and Process Description
Columbus McKinnon manufactures electrical and hand operated chain hoist equipment, and 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 16 April
2013.
Most of the hoist component parts are pre-caste or pre-molded metal pieces(i.e. different size metal hoist
housing),with the motors and other parts received as raw finished products.There are eight(8)assembly
work cells in the facility,which assemble the different types of hoists and chain pulleys that Columbus
McKinnon makes. The assembled hoists and chain pulleys are manually spray painted and labeled within
different paint spray booths. The metal grinding and sanding operations are done to smooth out the inner and
outer surfaces of the metallic hoist housing.A fabric filter is located inside the facility and is installed on
these two operations.This fabric-filtered air is exhausted to the inside of the building;the particulate is
collected inside a 55-gal drum.
Grinding metal parts generates metal particles that are collected by suction hoses immediately behind the
grinding wheel and then collected in a barrel;thus, it is a self-contained dust collection system.
a) Throughputs for 2013
Employees: 225 (219 in 2012)
Hours: I"shift 6:30AM—2:30PM,52 weeks/year(50 weeks in 2012)
2°a shift 2:30PM— 10:30PM, 52 weeks/year(50 weeks in 2012)
Paint used: In ES-1375 591 gallons-electrical booth(643 gallons used in 2011)
In ES-SPR-14 53 gallons-manual booth(65 gallons used in 2012)
In ES-SPR-9 113 gallons-manual booth(54 gallons used in 2012)
757 gallons total (762 gallons used in 2012)
Total VOCs 3.7 tons/7,354 lbs(2.9 tons/5,792 lbs in 2012)
Greatest HAP(Xylene) 0.71 tons/1,420 lbs(.75 tons/1,510lbs in 2012)
Total HAPS 1.1 tons/2,263 lbs(1.2 tons/2,448 lbs in 2012)

b) Permitted Sources
c tsbFo� n x "i
_ .j� I��o"5�N- ,���r�'� ,�' 3!���aR;�t* � x.i ���?p n �"• _
One paint spray booth(filter type)
i installed on a metal finishing
ES-1375 One spray paint booth with
operation
(NESHAP) CD-1375
panel filters
i Operating during inspection 0% S
I V.E.observed.
One paint spray booth(filter B e) CD- _,_.. .P p ...........
ES SPR-9 installed on a metal finishing One spray paint booth with !
(NESHAP) operation Operating during panel filters
inspection 0%V.E.observed.
i
I One paint spray booth(filter type)
installed on a metal finishing
ES-SPR-14 operation =_ One spray paint booth with
u CD-SPR-14
I (NESHAP) Operating during inspection 0% panel filters
V E observed.
Ji
rTcs'
gt—
�7 r,
IES FP-Foam Packaging ; No Yes j
Operating at the time of Inspection 2Q.0102(c)(2)(E)(i)
_.._ .. .. , 0102 c 2 E r f No '
IES 937-metal grinding operation I
Operating 1 time a week ( 2Q O( )( )O Yes
c)Insignificant Activities
3) Inspection Conference
On I I March 2014,I Mike Thomas of FRO DAQ met with Rena' Hart,Environmental Health and Safety
Manager, and Debbie Taylor, Office Manager with Columbus McKinnon.We discussed the following
a) Verified the FACFINDER information;no changes are necessary.
b) I observed the records and spreadsheets used to track the daily and monthly use of paint and VOCs.
They do an excellent job with record keeping.
c) Ms. Hart and I discussed the facility's need to remain subject to 6H requirements even though they do
not use coatings containing any of the listed metals. Ms. Hart decided that there was no reason to
remain subject to 6H. I will email the appropriate exemption form.

4) Inspection Summary
Ms.Hart led me on a tour of the facility,which was operating.I observed the following:
a) Spray Paint Booths
i) ES-1375—Electric hoists are painted here,with filters changed--2-3 times/week; it was operating and
I observed no problems.
ii) ES-SPR-9—The"entruck"hoists are painted here; it was not in operation at the time,but had
operated earlier in the day. I observed no problems.
iii) ES-SPR-14—The large"Shaw Box"brand hoists are painted here. This booth is totally enclosed and
has two types of filters, an intake filter in the ceiling and another large filter throughout the floor area.
These filters are"long-term"and are changed—every 3-4 months.All painting is done with both end
doors shut and once the hoist is completed, it is conveyed overhead via a transfer system to an infrared
drying area adjacent to the booth. The hoists are then dried for—30 minutes. This booth was operating
and I observed no problems.
All three active booths are clearly labeled,according to the permit Emission Source ID. There are currently
— 100 total hoists painted per day within all of the booths. Filters are changed between 2-3 times/week at
the end of I"shift, depending on the amount of paint that has been used. I noticed 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.
b) Spill Containment Areas: There are two spill'containment areas.The first area is where the bulk
transmission fluid is housed, and it contains a 3000-gallon holding tank where all used oils are stored.
When the tank is full,the oils are pumped out and disposed of as hazardous waste. The second area is
where a 1000-gallon holding tank is housed.This is where cleaning solutions,which are used to wash
the hoists before they are painted,are dumped and held before they are taken away as waste. Each 350-
gallon cleaning tank(there are four) contains approximately 200 gallons of cleaning solution(14
gallons of solvent are generally used per 350 gallons of water).Each cleaning tank has a MSDS sign
specifying what solvent is used in that tank.These tanks are dumped—every 2 weeks into the holding
tank and replaced with fresh solutions.
c) Foam Packaging Area(IES-FP): There are two sections where this packaging foam is dispensed, one
within the shipping area and the 2°d area near paint booth ES-1375. The system consists of a foam
packaging machine,which uses conventional packaging foam from 55 gallon drums. I saw no problems
here.
d) Metal Grinding Operation (IES-937): This area only operates—once a week and is used to grind
any pieces of metal off various facing parts. Once done,the operator sweeps up the metal fragments
and disposes of them. It was not operating during my inspection, and the area was fairly clean.
5) Permit Stipulations
a) A.2 2D .1111 MAXIMUMACHIEVABLE CONTROL TECHNOLOGY—Applicability of GACT
Subpart;n**-H"Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources"
Appeared to be in Compliance—The facility has switched to using paints that have no McCl, lead, or
chromium; all current painters were certified in spray gun equipment selection,techniques,
maintenance, and environmental compliance on 4 August 2013.

b) AA 2D .0515 PARTICULATES FROMMISCELLANEOUSINDUSTRLIL PROCESSES-
Particulate matter emissions shall not exceed allowable emission rates
Appeared to be in Compliance-Permit review demonstrates compliance.
c) A.5 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.7 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. There have been no complaints against the facility. Ms. Hart has not received any
complaints at the facility.
e) A.8 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.Ms. Hart does at least
one weekly walk-around to ensure compliance. The facility conducts annual staff training regarding
VOCs as well as training for new hires.
f) A.9 2Q .0711 TOXICAIRPOLLUTANTEMISSIONLIMITATION REQUIREMENT—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 latest submitted report stated emissions of 3.7 tons of all VOCs,
1,420 lbs. of Xylene(largest HAP) and 2,263 lbs. of all HAPs. These figures are well below their limit.
g) A.10 2Q .0803 COATING,SOLVENT CLEANINGAND 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 latest report, which was compliant and submitted on time,
stated total VOC emissions of 15.0 total tons, 0 .44 tons of Xylene(largest HAP),and 0.7 tons of all
HAPs.These figures are well below their limit.
6) 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.
7) DAQ Compliance History
None in the past 5 years.
8) Comments and Compliance Statement
Columbus McKinnon appeared to be in compliance on 11 March 2014.
/mst