AQ_F_0900049_20101216_CMPL_InspRpt

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NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Taylor Mfg
NC Facility ID 0900049
Inspection Report County/FIPS:Bladen/017
Date: 12/30/2010
Facility Data Compliance Data
Taylor Mfg Inspection Date 12/16/2010
1585 US 701 South Inspector's Name Pam Vivian
Elizabethtown,NC 28337 Operating Status Operating
Lat: 34d 36.7370m Long:78d 36.8200m Compliance Code Compliance-inspection
SIC: 3559/Special Industry Machinery Nec _ Action Code FCE
NAILS: 3331117 Farm Machinery and Equipment Manufacturing On-Site Inspection Result Compliance
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact permit 06963/R03
Denise Bridgers Denise Bridgers Charles King Issued 5/18/2006
Secretary Treasurer Secretary Treasurer Supervisor Expires 4/30/2011
[phone] [phone] [phone] Classification Small
Permit Status Active
Inspector's Signature: <j// ; Comments:
Date of Signature: I Z/3 O/Z 0
NESHAP Applicability:
Rule 6H applies for manganese in one of the products.
The IN was originally received by Central Office 17 March 2009. It appears FRO did not receive its copy. Ms.
Bridgers sent FRO a copy of it which included a copy of the green cards sent back to EPA and CO.
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 EQUIPMENT: Glasses in all areas,ear-plugs and hard hat-in fabrication and assembly areas.
PROCESS/FACILITY DESCRIPTION:
Taylor Manufacturing builds farm equipment,small metal storage buildings and wood/coal burning water heaters.
Taylor receives sheet metal and structural tubing. There are different buildings for the fabrication,assembly/welding,
and finishing of the products. The permitted emission sources are six spray booths each about 8 ft by 15 ft,large
enough to accommodate products. These booths are used for the painting of the product and the application of the
insulating foam.
PERMITTED EMISSION SOURCES:
Three(3)paint spray booths with 96 square feet of filter area each(ES1,ES2,and ES3);and
Three(3)paint spray booths with 156 square feet of filter area each(ES4,ES5,and ES6).
CURRENT THROUGHPUTS:
Number of Employees 25 (Several employees have been laid off due to economy)
Hours of Operations 7:30am to 3:30pm; 8 hrs/day;Mon-Thurs;Office opened on
Fridays

Opening Conference:
On 16 December 2010,1,Pam Vivian and Maureen Matroni-Rakes,both of DAQ FRO met with.Mr.Charles King,
Plant Supervisor and Ms.Denise Bridgers, Secretary/Treasurer and overall facility contact. I explained to both we
were at the facility to do a compliance inspection and to assist with their permit renewal with its emissions inventory.
Ms.Bridges said she was going to be submitting the inventory with the appropriate forms after the start of the New
Year. She said she believed she understood how to properly calculate the emissions and submit it. She noted she
would call us if she had any questions if she needed assistance. She explained that Mr.King would guide us on the
plant inspection but she needed to get back to some other pressing issues. I asked if she was still the overall contact for
the facility and she said no changes were necessary at this time. We thanked her and left with Mr.King.
Mr.King presented a copy of the permit. I asked.if the facility had changed anything since the last inspection and he
said nothing had changed except business is still slow. The facility did not use any styrene or MEK in their
manufacturing process during CY-2009 or 2010. I inquired if he had developed a method to show compliance for
stipulation A.7 on the permit for toxic.permit emission rates in lbs/hr for each of the chemicals listed within it. He said
he did devise a method after I discussed it with him last year and used the amount used in pounds and determined the
amount of time it was used to manufacture a unit. He said he gave the information to Ms.Bridgers the first part of last
year when I discussed it with him. He left to go find and discuss this with her but she had just left for another business
engagement. Mr.King said he would discuss this with her,find the records,and send a copy to our office. I noted it
was important that I receive this information for this facility to be in compliance. I reminded him the annual report for
stipulation A.8 was due by 1 March 2010.
Facility Inspection:
Mr.King guided us throughout the entire facility operation. In the metal fabrication building there were four
employees cutting and shaping various metal sheets. Mr.King noted the economy has slowed things down
tremendously and most of this building was rarely used. There are now about 4 separate work stations operating. He
noted he shifts employees around to cross train and keep everyone up to date with the entire process.
We went to the assembly/welding building where about 7 to 8 employees were manufacturing the heaters and other
metal frames and welding them together.
We went to the fmishing.building where the paint and insulating foam are applied to the final product. This building
has 6 separate spray booths in it but only three booths are operated(ES-1,ES-2, and ES-3). There is not enough
business to operate all six spray booths. Three.employees were working in this building. One was spraying black
paint onto a water heater and two others were applying insulating foam onto a water heater. Mr.King said it generally
takes about four.days from start to finish for one water heater. The booth filters appeared maintained and Mr.King
said they only need to change them about every 9 months.
We went to the warehouse where inventory is stored until shipped. Supplies necessary for manufacturing product is
also stored in this building. He noted a new product was started about S years ago. The company began
manufacturing road side metal ice houses. This has helped to keep business operating. I noted the need of receiving
the record showing the emission rate for Stipulation A.7. We thanked him and left.
STIPULATIONS:
A.3 2D.0515 PARTIUCLATE CONTROL REQUIREMENT—IN COMPLIANCE—During the inspection,I
did not observe any particulate emissions escaping the facility from the stacks and doorways. The 6 spray booths are
not all used because of the slow economy but each booth had filters and appeared to be well maintained.
A.4 2D.0521 VISIBLE EMISSIONS CONTROL REQUIREMENT—20%opacity limit. IN COMPLIANCE—
No VE was observed from the stacks and doorways.
A.6 2D.0958(c)WORK PRACTICES REQUIREMENTS-IN COMPLIANCE—There were no uncovered
containers of paint or other solvents observed during this inspection. Covered waste containers are at various
locations around the facility where manufacturing needs require disposal of such materials and had covers on each.
Mr.King said he reminds the employees of this work practice. All containers in the storage room were covered.

A.7 20 0711 TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT-The Permittee shall
limit the emissions of all TAPs,including styrene,toluene,MEK,and xylene to less than the TPER limit.
COMPLIANCE PENDING-Facility did not use MEK or styrene in the business for either CY 2009 or 2010. Mr.
King says he did develop a test method to measure the lbs/hr for toluene and xylene and gave the record of findings to
Ms.Bridgers. He will discuss with her,find record,and submit it to this office.
A.8 20.080 EXCLUSIONARY RULE REQUIREMENTS-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.
IN COMPLIANCE-The annual report for CY 2009 usage as Total VOCs—12,325 lbs;Greatest HAPs(toluene)
905 lbs;and Total HAPs-1374 lbs.
Reporting Requirements:
Annual report due on or before 1 March of each year and was received on 1 March 2010.
112r Status:
Based on observations and conversations with facility personnel,this facility does not meet the requirement
for a written Risk Management Program as required by 40 CFR 68,
S-YEAR COMPLIANCE HISTORY:
None is.found for this facility.
COMMENTS AND RECOMMENDATIONS:
Generally the facility appeared to be in compliance with its current air permit with the exception that it has not
submitted the required record showing compliance with Stipulation A.7. Although manufacturing processes using the
chemicals had drastically dropped off,Mr.King understands it is still necessary to be in full compliance. He will send
DAQ FRO this record once they find it. Ms.Bridgers plans to submit the emissions inventory via AFRO. She knows
to contact this office if she has any questions. I recommend calling Ms.Bridgers the first week of 2011 and inquire
about the necessary record. If FRO does not receive it by COB on 7 January 2011,send an NOV for non-compliance
of Stipulation A.7 for emission rates.
/pcv
cc: Central Files