AQ_F_0400030_20100729_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Coffing Hoists
NC Facility ID. 0400030
Inspection Report County/FIPS:Anson/007
Date: 07/30/2010
Facility Data Compliance Data
Coffing Hoists Inspection Date 07/29/2010
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 ContacTF
ed Contact Technical Contact permit 03671 /R09
Issued 10/16/2009
Linda Clappseo Linda Clappse Expires 9/30/2013
EH&S Managernager EH&S Manager Classification Small
(704)694-2156156 [phone] permit Status Active
Inspector's Signature: Comments:
Date of Signature:
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 approximately
11 'V2 miles to Laurel Hill. Turn right at Hwy 74 and go west about 35 miles to Wadesboro. Turn left onto Hwy
52 South and go approximately 1 1/2 miles to Country Club Road. Turn left and entrance to building is about 50
yards on right hand side. Enter at front office.
Safety considerations: Safety shoes and safety glasses.Hardhat and earplugs not necessary.Be aware of forklift
traffic when in the warehouse.
2) Facility and Process Description
Coffing Hoists Company manufactures electrical and hand operated chain hoist equipment. 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 16 September 2009.
This facility used to be permitted for two paint spray booths but,in its latest permit modification in October 2009,
is now permitted for five.They are used to paint the assembled hoists and pulleys.The fabric filter is located inside
the facility and is installed on several metal grinding and sanding operations.The fabric-filtered air is exhausted to
the inside of the building and the particulate is collected inside a 55-gal drum.Grinding metal parts generates meta I
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 worl;mg
operation; the scrubber is no longer needed due to the size of material collected). Most of the hoist components
parts are pre-caste or pre-molded metal parts (i.e. different size metal hoist housing). The motors and other parts
,tirnrinrtc ThP orinding and sanding operations are done at the facility to smooth snit

the inner and outer surfaces of the metallic hoist housing. There are eight(8) assembly work cells in the facility.
These work cells 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. The facility is an 180,000 sq. ft.
process and storage operation.The process area in the facility is about 60%,the storage area about 40%.
a) Throughputs for 2009
Employees: 197 (115 in 2008)
Hours: V shift 6:30AM—2:30PM, 50 weeks/year(same in 2008)
2°a shift 2:30PM— 10:30PM, 50 weeks/year(part time in 2008)
Paint used: In ES-1375 711 gallons-electrical booth(1329 gallons in 2008)
In ES-0704 374 gallons-manual booth (574 gallons in 2008)
1085 gallons total (1903 gallons in 2008)
Total VOCs 3.4 tons (6,763 lbs) (5.7 tons in 2008)
Greatest HAP (Xylene) .86 tons (1,711.6 lbs) (1.6 tons in 2008)
Total HAPS 1.44 tons(2,879 lbs) (2.65 tons in 2008
b) Permitted Sources
Control Control System
Emission Source
Emission Description-,
Source lD Description System ID Descri p,tion
ES-1375 One paint spray booth(filter type) CD-1375 One spray paint booth with
panel filters
(NESHAP) installed on a metal finishing operation _
One spray paint booth with
ES-0704 One paint spray booth(filter type) CD-0704 panel filters
(NESHAP) installed on a metal finishing operation _
ES-SPR-7 One paint spray booth(filter type) One spray paint booth with
CD-SPR-7
panel filters
(NESHAP) installed on a metal finishing operation
One spray paint booth with
ES-SPR-9 One paint spray booth(filter type) CD- panel filters
(NESHAP) installed on a metal finishing operation _ -One spray paint booth with
ES-SPR-14 One paint spray booth(filter type) CD-SPR-14 panel filters
(NESHAP) installed on a metal finishing operation
c) Insignificant/Exempt Activities
Source of Source of Title V
Source Exemption Regulation TAPs? Pollutants?
.0102
2 c 2 i No Yes
IES-FP-Foam Packaging Q O( )(E)(i)
0102 c 2 E r No Yes
IES-937 -metal grinding operation 2Q O( )( )(i) _
3) Inspection Conference
On 29 July 2010,1 (Cindy Grimes) met with Linda Clappse,Environmental Health and Safety Manager, and
Debbie Taylor,Office Manager. We discussed the following:
a) Verified the FACFINDER information as being correct.
b) They have received a new permit reflecting some modifications to their permit since I was here last year,
Three paint booths that were transferred from a Michigan plant have been installed and added to their permit
as part of the modification.
c) The oldest paint spray booth (ES-0704) is no longer in operation and has been removed. Thus, there are
currently a total of four operational paint booths.

d) Ms. Clappse has been very diligent regarding the new NESHAP Subpart 6H,which goes into effect 11
January 2011. I gave her a copy of our checklist we will be using during future inspections. She is aware of
the recordkeeping the facility will need to do,including the following:
i) Painter training certification—On 4 August 2010, a certified paint trainer(Maylon Cooke) from High
Point Pneumatics in High Point is coming to Coffing Hoists to present a course on paint spray booths,
paint nozzles, and clean up procedures to all the painters here.Apparently,Mr. Cooke is a specialist in
material handling and paint spray equipment.Ms. Clappse will have these records available to me for the
next compliance inspection.
ii) Ms. Clappse showed me documentation for the paint booths' filters 99% efficiency.
iii) Ms. Clappse will have the written documentation needed for the paint spray guns by the compliance date
of 1 January 2011.
iv) They do not do any paint stripping here and use no McCI.
e) I observed the records and spreadsheets kept regarding the daily and monthly totals of paint used and
VOCs. They are still doing 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. They
are still using the same kind of paint at all times, so the VOCs remain fairly consistent.
f) 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. I observed the following:
a) Paint Booths
i) ES-1375—Electric hoists are painted here,with filters changed—2x/week; it was operating.
ii) ES-0704—This booth is no longer operating and has been removed from site.
iii) ES-SPR-7—This booth is where rotoblasting takes place; it was not operating.
iv) ES-SPR-9—This is the"entruck"booth,where this particular type of hoist is painted; it was
operating.
v) ES-SPR-14—This is the"Shaw Box"booth,where the"Shaw Box"brand is painted.The booth is
totally enclosed and has two types of filters, 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 hoists total painted per day within all of the booths. Filters are changed b/t 2-3
times/week, depending on the amount of paint used, and they are changed at the end of Is` 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.
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 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: 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.
5) Permit Stipulations
a) A.2 2D.1111 MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY—Applicability of GACT
Subpart HHHHHH"Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources"
In Compliance—This stipulation is due to go into effect 10 January 2011,and Ms. Clappse is very aware of
it. During the 2009 inspection,I had looked at several paint and solvent MSDSs,and I verified that the facility
uses no McCl. The total lead usage in 2008 was 4.66 lbs and for chromium .28 lbs (from the emissions
inventory). Both of these metals are in paint B62Y17.During next year's inspection, it should be verified
that all of the painters here were certified in spray gun equipment selection,techniques,maintenance, and
environmental compliance.
b) A.4 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES-
Particulate matter emissions shall not exceed allowable emission rates
In Compliance—Current emissions inventory and permit review demonstrate 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.
In Compliance- I observed no visible emissions during my inspection.
d) A.7 2D .0540 FUGITIVE DUST CONTROL REQUIEMENT—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.
e) A.8 2D .0958(c) WORKPRACTICES 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. Ms. Clappse does at least a weekly walk
around to ensure that they comply with this requirement.
f) A.9 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.
In Compliance-The 2009 report stated emissions of 3.4 total tons of VOCs, .86 tons of Xylene(largest
HAP), and 1.44 tons of all HAPs. These figures are well below their limit
7) Reporting Requirements
Annual report is due by 1 March each year;report was received on time.
8) 112R Status
Based on the facility's inventory, it was decided that they are not subject to 112R requirements.
9)• 5 Year Compliance History
14 June 2004—NOV for late annual reporting.
10) Comments and Compliance Statement
This facility makes an effort to employ good work practices. It also keeps excellent records and
spreadsheets of the VOC-containing materials. Ms. Clappse is making the employees well aware of the
new MACT regulations in order to be compliant by 11 January 2011.
Coffing Hoists appeared to be in compliance on 29 July 2010.
/clg
cc: DAQ Central Files