AQ_F_0400030_20110621_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Coffing Hoists
NC Facility [D 0400030
Inspection Report County/F[PS:Anson/007
Date: 06/21/2011
Facility Data Compliance Data
Coffing Hoists Inspection Date 06/21/2011
2020 Country Club Road Inspector's Name Cindy Grimes
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
Linda Cla se Joe Ombrello Linda Clappse Issued 10/16/2009
1 p Expires 9/30/2013
EH&S Manager General Manager EH&S Manager Classification Small
[phone] [phone] [phone] permit Status Active
Inspector's Signature: ` 1 ' _ � Comments:
Date of Signature: 'j 14(Z'Zio
GACT/MACT Applicability: MACT Subpart 6H-Paint Stripping & Miscellaneous Surface Coating
Operations-subject,since facility uses surface coatings with chromium and lead (no manganese, nickel,
or cadmium); facility does not use any paint stripping containing MCCI. MACT Subpart 4Z—
Reciprocating Internal Combustion Engines—not subject,since 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 '/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 ''/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 fo•ldift traffic in the warehouse.
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 29
Ju ty 2010.
Most of the hoist components parts are pre-caste or pre-molded metal pants(i.e. different size metal hoist
housing),with the motors and other parts received as raw finished products. There are eight(8)assembly wort:
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 was put into storage for the time being.Three"new"paint booths were
installed(ES-SPR-7, 9, and 14), one remained(ES-1375),and ES-0704 spray paint booth was disassembled
and removed. Thus,there currently are four operational spray paint booths here.
a) Throughputs for 2010
Employees: 210 (197 in 2009)
Hours: I"shift 6:30AM—2:30PM, 52 weeks/year(50 weeks in 2009)
2"d shift 2:30PM— 10:30PM, 52 weeks/year(50 weeks in 2009)
Paint used: In ES-1375 699 gallons-electrical booth(711 gallons in 2009)
In ES-SPR-14 115 gallons-manual booth (374 gallons in 2009)
814 gallons total (1085 gallons in 2009)
Total VOCs 2.4 tons/4,767 lbs(3.4 tons/6,763 lbs in 2009)
Greatest HAP(Xylene) .5 ton/1,013 lbs (.86 tons/1,711.6 lbs in 2009)
Total HAPS .88 ton/1,759 lbs (1.44 tons/2,879 lbs in 2009)
b) Permitted Sources
Emnssnon` rEntrssndnonroc s Coutroh QonholSyskem
_ �3 . 1eSetipll. °,..�.-ts�, t�Ystgil)Tp ' '1i °'-besar lion
soutce.IA is 3 �.�— P
(NESHAP)
One paint spray booth(filter type) One spray paint booth with
NESHAP installed on a metal finishing operation CD-1375 panel filters _
ES-0704 One paint spray booth(filter type) One spray paint booth with
(NESHAP) installed on a metal finishing operation CD-0704 _ panel filters
ES-SPR-7 One paint spray booth(filter type) One spray paint booth with
_(NESHAP) installed on a metal finishing operation CD-SPR-7 �_ panel filters J
ES-SPR-9 One paint spray booth(filter type) One spray paint booth with
(NESHAP) installed on a metal finishing operation CD-SPR-9 panel filters
ES-SPR-14 One paint spray booth(filter type) CD-SPR-14 One spray paint booth with
(NESHAP) installed on a metal finishing operationil panel filters
c) Bnsignifncant/Exempt Activities
s' � 4 � Sours ce of Soo ce 6f Tifle p
Sogrce ExemptnonxRegulatimn'� ��
, � r a 7a , ,t TAPs� L 'ollutants? r
IES-FP-Foam Packaging I 2Q .0102 (c)(2)(E)(i) I No Yes I
IES-937 -metal grinding operation I 2Q .0102(c)(2)(E)(i) I No Yes
3) Inspection Conference
On 21 June 2011, 1 (Cindy Grimes) met with Linda Clappse,Environmental Health and Safety Manager,and
Debbie Taylor, Office Manager. We discussed the following:
a) Verified the FACPINDER information as being correct(Ms. Clappse's VA # is 276-475-3124, ext 1231).

b) Ms. Clappse has been very diligent regarding the new NESHAP Subpart 6H, which went into effect 9
January 2011. We thoroughly discussed the requirements last year,as it applies to the facility's
"Miscellaneous Surface Coating Operations", so she is aware of what they need to do, and are doing, to
comply. The results are within the inspection summary. She also has an electronic virtual/hands-on paint
training manual on her computer as part of her 6H program for the facility.
e) I observed the records and spreadsheets kept regarding the daily and montlily totals of paint used and
VOCs. They do an excellent job with the record keeping,and they keep a running month to month total
throughout the year,instead of just totaling all the months at the end of each year.The VOCs remain fairly
consistent, as the paints haven't changed.
t) I met briefly with Joe Ombrello,Executive Director and Authorized Contact at this facility,explaining that
I was there to conduct a compliance inspection.
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 every other day; it was operating.
ii) ES-0704—This booth is no longer operating and has been removed from site.
iii) ES-SPR-7—The rotoblasting booth, where abrasive blast cleaning of the hoist is clone, to
condition the hoists' surface for painting; it operates—2-3 times/week and was not operating
during inspection.
iv) ES-SPR-9—The "entruck" booth,where this particular type of hoist is painted; it was operating.
v) ES-SPR-14—The"Shaw Box"booth,where the"Shaw Box"brand hoist is painted.The booth
is totally enclosed and has two types of fitters, an intake filter in the ceiling and another filter
throughout the floor area; it was operating.
All of these active booths were 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;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 bull(
transmission fluid is housed, and it contains a3000-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-gal Ion
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 approximately every 2 weeks into the holding-
tank and replaced with fresh solutions.
c) Foam Packaging Area (IES-FP): This section is within the shipping area and was operating during
my inspection. It 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 fiagments
and disposes of them. It was not operating during my inspection, and the area was fairly clean.

e) Miscellaneous Surface Coating Operations (GACT 6H)
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 trainin,
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 6H; 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.
5) Permit Stipulations
a) A.2 2D .I I I I MAXIMUMACHIEVABLE CONTROL TECHNOLOGY—Applicability of GACT
Subpart HHHHHH"Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources"
In Compliance—Facility uses no McCI; in 2010,total lead usage was .34 Ibs, total chromium usage was
.02 lbs(both of these metals are in paint B62Y17); all painters were certified in spray gun equipment
selection,techniques, maintenance, and environmental compliance on 4 August 2010. For detailed
compliance summary, see e) Miscellaneous Surface Coating Operations section above within
inspection summary.
b) AA 2D .0515 PARTICULATES FROMMISCELLANEOUS INDUSTRIAL PROCESSES-
Particulate matter emissions shall not exceed allowable emission rates
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.
Hr Compliance-I observed 0%VE from all sources during my inspection.
d) A.7 2D.0540 FUGITIVE DUST CONTROL REQUIRNIENT—The Permittee shall not cause or
allow fugitive dust emissions to contribute to complaints.
In Compliance—I observed no fugitive dust emissions. This facility has all paved haul roads,and
there have been no complaints against 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.
In Compliance- I found that this facility's handling, cleaning and storage of all their paints, solvents
and thinners complied 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. Clappse does at
least one weekly walk-around to ensure compliance.

t) A.9 2Q .0711 TOXICAIR POLL UTANTEMISSIONLIMITATIONREQUIREMENT—The
Perm ittee shall maintain records of operational information demonstrating that the TAP emissions do not
exceed the TPER listed as MIBK 52 lbs/day,Toluene 98 Ibs/day, and Xylene 57 lbs/day.
In Compliance—The latest submitted report stated emissions of 2.4 tons of all VOCs, 1,013 Ibs. of
Xylene(largest HAP)and 1,759 lbs. of all HAPs.These figures are well below their limit.
g) A.10 2Q .0803 COATING, SOLVENT CLEANINGAND GRAPIIICARTSEXCLUSIONARY
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.
In Compliance-The latest report,which was compliant and submitted on time,stated total VOC
emissions of 2.4 total tons, .50 tons of Xylene(largest HAP),and .88 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. Clappse is making the employees well aware of the new MACT regulations
and got the facility into compliance well before the 9 January 2011 compliance date. She has a separate and
organized binder containing documentation of the spray painters training certification,the spray gun
specifications, and the paint filter specs.
Coffing Hoists appeared to be in compliance on 21 June 2011.
/clg
cc: DAQ Central Files