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HomeMy WebLinkAboutAQ_F_0400030_20130416_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office _ AIR QUALITY Coffing Hoists NC Facility ID 0400030 Inspection Report County/F1PS: Anson/007 Date: 04/18/2013 Facility Data Compliance Data Coffing Hoists Inspection Date 04/16/2013 2020 Country Club Road Inspector's Name Mike Thomas Wadesboro,NC 28170 Operating Status Operating Lat: 34d 56.5990m Long: 80d 3.1730m Compliance Code Compliance-inspection SIC: 3536/Hoists,Cranes,And Monorails Action Code FCE NAICS: 333923/Overhead Traveling Crane,Hoist,and Monorail System On-Site Inspection Result Compliance Manufacturing Contact Data Permit Data Facility Contact Authorized Contact Technical Contact Permit 03671/R09 Rena'Hart Joe Ombrello Rena' Hart Issued 10/16/2009 EH&S Manager General Manager EH&S Manager Expires 9/30/2013 (704)694-2156 (704)694-2156 (704)694-2156 Classification Small Permit Status Active Inspector's Sig tur Comments: 7 � I Date of Signature: e 1 (l Z S Zo/3 GACT/MACT Applicability:Subject to MACT Subpart 6H-Paint Stripping & Miscellaneous Surface Coating Operations—facility uses surface coatings with chromium and lead(no manganese,nickel,or cadmium); facility does not use any paint stripping containing McCI. Not subject to MACT Subpart 4Z— Reciprocating Internal Combustion Engines—facility has no emergency generators. 1) Location Coffing Hoists 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 '/2 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 1/2 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 Coffing Hoists Company manufactures electrical and hand operated chain hoist equipment, and is a Division of Columbus McKinnon Corporation.This facility operates under Air Permit No.3671R09, effective from 16 October 2009 until 30 September 2013. Cindy Grimes conducted the last compliance inspection on 21 June 2011. Most of the hoist components parts are pre-caste or pre-molded metal parts (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 Coffing Hoists 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,and 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 system(Note: A wet scrubber used to be permitted here for the metal working operation; the scrubber is no longer needed due to the size of material collected).The total facility is an 180,000 sq. ft. process and storage operation,the process area being-60% and the storage area-40%. Note: Coffing Hoists has undergone various physical changes since 2009,due to one of their plants in Michigan shutting down. Some of that plant's newer equipment was brought to Wadesboro and was either incorporated into its production or put into storage for the time being.Three"new"paint booths from Michigan were added to the permit(ES-SPR-7, 9, and 14),but only two were actually installed(ES-SPR-9 and 14). One original booth remained(ES-1375) and ES-0704 spray paint booth was disassembled and removed. Thus,there currently are three operational spray paint booths here. a) Throughputs for 2012 Employees: 225 (219 in 2012) Hours: l't shift 6:30AM-2:30PM, 52 weeks/year(50 weeks in 2012) 2nd shift 2:30PM- 10:30PM, 52 weeks/year(50 weeks in 2012) Paint used: In ES-1375 643 gallons-electrical booth(699 gallons-used in 2011) In ES-SPR-14 65 gallons-manual booth(115 gallons used in 2011) In ES-SPR-9 54 gallons-manual booth 762 gallons total 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/1,510 lbs in 2012) Total HAPS 1.1 tons/2,263 lbs (1.2 tons/2,448 lbs in 2010) b) Permitted Sources _ )Wnsiot »mission Source _.._. Control Gontipl5ystgin m_ Source ID 'Descrrphon: System ID - DescripGlon One paint spray booth(filter type) installed on a metal finishing ES-1375 operation CD-1375 One spray paint booth with (NESHAP) Operating during inspection 0% panel filters V.E.observed. One paint spray booth(filter type) ES-0704 One spray paint booth with (NESHAP) installed on a metal finishing CD-0704 panel filters operation One paint spray booth(filter type) ES-SPR-7 One spray paint booth with installed on a metal finishing ( CD-SPR-7 (NESHAP) h panel filters operation ,] ES-SPR-9 One paint spray booth(filter type) One spray paint booth with (NESHAP installed on a metal finishing CD-SPR-9 g J panel filters . Endgsion Emission Source ,Control Control System Source ID Dese p tioq System ID Dcsc�iption .- a _W operation Operating during inspection 0% V.E.observed. Source of Source of ptyIe V Sourccxempttogggt)aton TAPs7 ._ 'ollutants , O eratin at _ _...: - . IES-FP-Foam Packaging 2Q 0102(c)(2)(E)(i) No Yes Operating the time of Inspection IES-937-metal grinding operation 2Q.0102(c)(2)(E)(i) No Yes Operating 1 time a week_. W._..� One paint spray booth(filter type) installed on a metal finishing ES-SPR-14 operation CD-SPR-14 One spray paint booth with (NESHAP) Operating during inspection 0% panel filters V.E.observed. c.Insignificant/Exempt Activities 3) Inspection Conference On 16 April 2013, I Mike Thomas of FRO DAQ met with Rena' Hart,Environmental Health and Safety Manager, and Debbie Taylor, Office Manager.This was a prearranged inspection to discuss permit renewal and to assist with their Emissions Inventory. a) Verified the FACFINDER information;Ms. Clappse is no longer with the facility in Wadesboro. Ms. Hart has taken over her responsibilities. b) Ms.Hart informed me of several pieces of equipment that are no longer physically at the facility. These items will be pink sheeted to be removed during the upcoming permit renewal. c) 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. 4) Inspection Summary Ms. Clappse and Ms.Taylor 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-0704-This booth is no longer operating and has been removed from site. iii) ES-SPR-7-This booth is no longer operating and has been removed from site. _ iv) 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. v) 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 1D.There are currently - 100 total hoists painted per day within all of the booths.Filters are changed between 2-3 times/week depending on the amount of paint used,and they are changed at the end of I"shift.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 MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY-Applicability of GACT Subpart TIH*Hi 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 2010. For detailed compliance summary, see Miscellaneous Surface Coating Operations section after Section 9. b) AA 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL 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 haul roads, and there have been no complaints against the facility. Ms.Hart has not received any complaints at the facility. e) A.8 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.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 TOXIC AIR POLLUTANT EMISSION LIMITATION 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 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 latest report, which was compliant and submitted on time, stated total VOC emissions of 3.7 total tons, .71 tons of Xylene(largest HAP), and 1.1 tons of all HAPs.These figures are well below their limit. 6) Reporting Requirements Annual report is due by 1 March to comply with 2Q. 0803. 7) 112R Status This facility neither uses nor stores chemical compounds that require a written risk management plan under the Clean Air Act, Section 112R. 8) DAQ Compliance History a) 14 June 2004—NOV for late annual reporting 9) Comments and Compliance Statement This facility makes an effort to employ good work practices and keeps excellent records and spreadsheets of all materials used here. Ms. Hart has a separate and organized binder containing documentation of the spray painters training certification,the spray gun specifications, and the paint filter specs. Photographs of the emission sources; they are located on the G-Drive, DATA,DAQ, Anson, Coffing Hoists,PICS. Coffing Hoists appeared to be in compliance on 16 April 2013. Miscellaneous Surface Coating Operations (GACT 611) Requirements i) Use of HVLP(high volume, low pressure) spray guns—verified through manufacturer documentation, provided by facility. ii) Prep Station/Spray Booth must have full roof and at least 3 walls or side curtains—verified during inspection. iii) Filters must be>98% efficient—verified through Columbus Industries(filter manufacturer) documentation,provided by facility;filters are documented to be 99.8% efficient. iv) Painters must complete certification training(initial training valid for 5 years, with refresher training repeated every 5 years)—verified with training certificates (dated 4 August 2010), through High Point Pneumatics(trainer Myland Cook),provided by facility. v) Acceptable means of spray gun cleaning, including hand washing, manual flushing, and using enclosed gun washer—verified during inspection(facility uses enclosed gun washer). Notification i) Initial notification by 9 January 2010—FRO DAQ received on 3 February 2009, stating facility's applicability to 611; notification indicated facility was in compliance. ii) Compliance status by 9 January 2011, plus 60 days—facility certified compliance within initial notification on 3 February 2009; also verified during inspection. iii) Annual change notification by 1 March—facility will comply if applicable. Recordkeeping i) Records must be kept for minimum 5 years documenting the following: spray painter certification, filter efficiency, spray gun HVLP verification,notifications, deviation from requirements, and compliance assessment records—records verified during inspection; facility will comply with time frame for records retention. /mst