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Home My WebLink AboutAQ_F_0500075_20220914_CMPL_InspRpt NORTH CAROLINA DIVISION OF Winston-Salem Regional Office AIR QUALITY Halcore Group,Inc.dba American Emergency Vehicles Inspection Report NC Facility ID 0500075 Date: 09/14/2022 County/FIPS:Ashe/009 Facility Data Permit Data Halcore Group,Inc. dba American Emergency Vehicles Permit 10496/R02 101 AEV Lane Issued 2/14/2022 Jefferson,NC 28640 Expires 4/30/2024 Lat: 36d 25.5501m Long: 8ld 28.9002m Class/Status Small SIC: 3711 /Motor Vehicles And Car Bodies Permit Status Active NAILS: 336211 /Motor Vehicle Body Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP MACT Part 63: Subpart 6C,Subpart ZZZZ Gary Graybeal Barry DeRousse Jeff Dreyer Compliance Manager Vice President/General Process Control Manager (336)977-7203 Manager (336)846-8010 (336)846-8010 Compliance Data Comments: Inspection Date 09/08/2022 Inspector's Name Ryan Dyson Inspector's Signature: Z� DMM Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: 9/14/2022 Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP No emissions inventory on record. The emissions inventory is due 01/31/2024. *Highest HAP Emitted inpounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 09/23/2021 NOV/NRE 2Q .0101 Required Air Quality Permits 02/14/2022 01/09/2019 NOV 2Q .0 10 1 Required Air Quality Permits 03/19/2019 Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested 1 Permitted Sources Emission Emission Source Co ntrol Control System Source ID Description 7 S ystem ID Description FSpray Booths ES-2 dry filter-type paint spray booth equipped with natural gas-fired N/A N/A direct-fired burner(3.58 million Btu per hour maximum heat input rate) ES-3,ES-5 two dry filter-type paint spray booths each equipped with a natural gas- fired direct-fired burner N/A N/A (3.11 million Btu per hour maximum heat input rate) ES-4,ES-12,ES-13 three dry filter-type paint spray booths each equipped with a natural gas- N/A N/A fired direct-fired burner (3.4 million Btu per hour maximum heat input rate) Gluing Operations ES-1,ES-8 two glue booths N/A N/A ES-9,ES-10,ES-11, three glue stations N/A N/A Misc.Sources ES-6 wood working operations CD-6 fabric filter (1,830 square feet of filter area) ES-7 solvent recovery process with integral process condenser N/A N/A Insignificant/Exempt Activities Exemption Source of Source of Source Regulation TAPs? Title V 7 Pollutants? I-ES-1 -body prep areas(4 total)equipped with two(2) 2Q 0102 natural gas-fired pressure washers(0.82 million Btu per hour maximum heat input rate total) (h)(1)(B) I-ES-2-welding operations I-ES-3 -natural gas-fired emergency generator(100 kW rated capacity) [NESHAP-ZZZZ] I-ES-6-drying booth equipped with a natural gas-fired 2Q .0102 (h)(5) Yes Yes burner(2.0 million Btu per hour maximum heat input rate) IES-4-above-ground gasoline storage tank(500-gallon capacity) [NESHAP—CCCCCC] 2Q .0102 (g)(4) IES-5-above-ground diesel storage tank(500-gallon capacity) 2 Introduction On September 8,2022,Mr.Ryan Dyson,Environmental Specialist for the Winston-Salem Regional Office of the North Carolina Division of Air Quality(WSRO-DAQ),met with Mr. Gary Graybeal,Compliance Manager and Mr.Mike Absher,Maintenance Manager,for an unannounced Full Compliance Evaluation(FCE)of Halcore Group,Inc.dba American Emergency Vehicles.This facility was most recently inspected as part of a Partial Compliance Evaluation(PCE)conducted by Mr.Dyson on September 2,2021. At the time of that PCE,the facility was found to be in violation of 15A NCAC 02Q .0101,"Required Air Quality Permits,"for constructing and operating a source subject to an applicable standard,requirement,or rule that emits any regulated pollutant without obtaining an air quality permit for that equipment,and North Carolina General Statute 143-215.108,for altering or changing the construction or method of operation of any equipment or process from which air contaminants are or may be emitted,without permit coverage for that equipment and/or activity.This stemmed from the facility having re-located emission sources from their other location(Facility ID#0500068)and placing them in operation at this location without permit coverage.The facility's current permit (Permit#10496R02)was issued on February 14,2022 to incorporate these changes,as well as the additions of three new paint spray booths(ES-4,ES-12 and ES-13).Mr. Graybeal indicated that the demand for their products has never been higher,but their production is steady,as it has been somewhat limited by supply chain and staffing issues.Mr.Graybeal confirmed that the facility operates from 6:30AM to S:OOPM,Monday through Thursday,for 50 weeks per year. The facility also operates on occasional Fridays. All IBEAM contact information was confirmed by Mr.Graybeal at the time of this inspection. Safety Equipment Proper Personal Protective Equipment(PPE)for this facility includes safety shoes,hearing protection and eye protection. Applicable Regulations Permit Condition A.1 states that the facility is subject to the following regulations:Title 15A North Carolina Administrative Code (NCAC), Subchapter 2D.0202,2D .0512,2D .0515,2D .0516,2D .0521,2D.0535,2D .0540,2D .0611,2D .I I 11 (40 CFR Subparts ZZZZ and CCCCCC),2D .1806,and 2Q.0711. This facility is not subject to the Risk Management Plan(RMP)requirements of the 112(r)Program,as it does not purchase,produce,utilize,or store any of the regulated substances in quantities above their associated threshold limits. The facility is still subject to the General Duty clause in this rule. Discussion The facility refurbishes ambulances by removing the bodies of existing ambulances to remount them on new frames. Some of the ambulances also receive paint and internal cabinetry work,when desired by the customer.The process begins with the disassembly and removal of the body from the existing chassis.The rear box is then prepped for painting(if required)in the four exempt body prep areas with two natural gas-fired pressure washers(I-ES-1).One of these body prep areas appeared to be in active use,with the pressure washing of a truck body occurring at the time of this inspection.If necessary,the body and box are also sent to the exempt welding operations(I-ES-2),which were in operation at the time of this inspection.It should be noted that the welding operations at the facility do not currently exhaust out to the atmosphere.Mr.Graybeal indicated that the facility is considering the possibility of routing the welding operations out to the atmosphere in the future but would consult with permitting staff at the WSRO-DAQ prior to initiating this process. If the body and box are to be re-painted,then they are sent to the dry filter prime spray booths with natural gas fired direct burners (ES-3 and ES-5).These booths were observed on-site but did not appear to be in operation at the specific time of this inspection. Nevertheless,the filters appeared to be properly installed with no discernible gaps or holes.The facility keeps filter change records posted beside each paint spray booth.These records indicate that the exhaust blanket filters are typically changed on a weekly basis. After priming,the body and box can be painted in any of the facility's production dry filter paint spray booths with associated natural gas-fired burners(ES-2,ES-4,ES-12,or ES-13).ES-4,ES-12 and ES-13 had just completed their installation processes approximately a week before this inspection,according to Mr.Graybeal.ES-4 and ES-13 were observed in operation with no discernible visible emissions at the time of this inspection. The facility is also permitted for two glue spray booths(ES-1 and ES-8).Neither of these glue booths were observed in operation at the time of this inspection.Mr. Graybeal indicated that the facility is planning on re-locating ES-1 to be positioned beside ES-8 in the future.Furthermore,the facility is planning on replacing ES-8 with a newer,like-for-like glue booth in the future.Mr. Graybeal provided a copy of an email he had sent to Mr.Jim Hafner,Acting Permits Coordinator for the WSRO-DAQ,regarding this issue and it did not appear that a permit modification,or any modeling would be required to be conducted in the event of this replacement and re-location.Mr.Hafner appeared to cite 15A NCAC 02Q.0102(g)(1)(E)in this matter.More information pertaining to this is covered in the permit issues/considerations section of this report.The glue booths are used to glue the cabinetry and other interior pieces prior to the remounting of the box. 3 The facility also has three small glue spray stations for touch ups that don't exhaust to the atmosphere(ES-9,ES-10 and ES-11).A water-based glue(3M Fastbond Foam Adhesive 100NF)is used exclusively in these three small stations.Mr. Graybeal indicated that the facility may consider routing these three small stations to the atmosphere in the future,and that is why they requested that they be permitted. The facility's woodworking equipment(ES-6)was observed in operation at the time of this inspection. These woodworking operations appear to consist of multiple table saws and two CNC routers.The emissions from the woodworking operations(ES-6)are controlled by a fabric filter(CD-6),which was also observed in operation with no discernible visible emissions at the time of this inspection.The facility is also permitted for a solvent recovery process with an integral process condenser(ES-7). This equipment had been used to recover MEK.However,this unit is currently disconnected.Mr. Graybeal indicated that the facility was informed by insurance personnel that they should construct a separate building outside of the main facility to house this unit,and the facility decided it did not appear cost-effective to do so.Mr. Graybeal indicated there are currently no plans to bring this unit back online.The most recent permit issuance also covered the addition of three exempt sources,including a 500-gallon aboveground gasoline storage tank(IES-4), a 500-gallon aboveground diesel storage tank(IES-5)and a drying booth equipped with a natural gas-fired burner(I-ES-6).The two storage tanks(IES-4 and IES-5)were brought over from facility ID#0500068.Mr.Graybeal indicated that these two tanks sit in dry storage in a shed on the property and will likely never be placed in service at the facility.Mr.Absher indicated that the facility may be in the process of removing these tanks altogether.The drying booth(I-ES-6)is a new installation. It was observed on-site,but Mr. Graybeal indicated it hasn't yet been placed in operation.Lastly,the facility's 100 kW rated capacity natural gas-fired emergency generator was also observed on-site. This generator was not in operation,and its hour meter read 360.5 hours at the time of this inspection. Permit Conditions Condition A.2 contains the permit renewal and emission inventory requirement of 15A NCAC 2D.0202. To meet this requirement, the facility must submit a permit renewal request and air pollution emission inventory report for the 2022 calendar year at least 90 days prior to the expiration date of the permit. The current permit for this facility expires April 30,2024. This condition was discussed with Mr. Graybeal at the time of inspection and future compliance is anticipated. Condition A.3 contains the particulate control requirement of 15A NCAC 2D.0512,"Particulates from Wood Products Finishing Plants."To comply with this condition,the facility must not discharge particulate matter stemming from the working,sanding,or finishing of wood without providing for its collection,adequate duct work and properly designed collectors.All ductwork at the facility appeared to be properly constructed and maintained,and records were provided to Mr.Dyson at the time of inspection to demonstrate that inspections and maintenance of the fabric filter unit are occurring in a timely manner,as described below. Compliance with this condition is indicated. Condition AA contains the particulate control requirement of 15A NCAC 2D.0515.To comply with this condition,the particulate matter emissions from the emission sources at this facility must not exceed allowable emission rates,as derived from the following equations,where P is the process throughput rate in tons per hour(tons/hr.)and E is the allowable emission rate in pounds per hour (lbs./hr.). E=4.10 * (P)0" for P<=30 tons/hr.,or E=55 * (P)0`1-40 for P>30 tons/hr. The following table,compiled from the facility's permit reviews,demonstrates that the anticipated controlled emission rates are less than the allowable emission rates.Compliance with this condition is indicated. Process Weight Rate(P) Allowable Emission Rate Anticipated Controlled Emission Source(ID No.) [tons/hr.] (E) [lb.PM/hr.] Emission Rate [lb. PM/hr.] Glue Spray Booth(ES-1) F 0.0135 0.229 0.00 Dry Filter Paint Spray Booth(ES-2) 0.0135 0.229 0.0233 Dry Filter Prime Spray Booth(ES-3) F 0.0135 0.229 0.0233 Body Prep Areas(I-ES-1) 0.000125 0.0099 0.00608 4 Process Weight Rate(P) Allowable Emission Rate r nticipated Controlled Emission Source(ID No.) [tons/hr.] (E) [lb.PM/hr.] Emission Rate [lb. PM/hr.] Welding Operations(I-ES-2) 0.000185 0.0129 0.00285 Dry Filter Paint Spray Booth(ES-4) 0.00044 0.0217 0.0131 Dry Filter Prime Spray Booth(ES-5) 0.00044 0.0217 0.0131 Dry Filter Paint Spray Booth(ES-12) 0.00465 0.112 0.06 Dry Filter Prime Spray Booth(ES-13) 0.00465 0.112 0.06 Condition A.5 contains the sulfur dioxide control requirement of 15A NCAC 2D.0516. To comply with this condition,sulfur dioxide emissions from the facility's combustion sources must not exceed 2.3 pounds per million Btu heat input.According to the facility's most recent Permit Review,R02,written by Mr.Hafner and dated February 14,2022,the actual sulfur dioxide emissions from the natural gas-fired burners are calculated to be 0.0006 lb./MMBtu.Compliance with this condition is indicated. Condition A.6 contains the visible emissions control requirement of 15A NCAC 2D .0521.To comply,visible emissions from emission sources manufactured after July 1, 1971,shall not exceed 20 percent opacity when averaged over a six-minute period,except that six-minute periods averaging not more than 87 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour period.No visible emissions were observed from any of the facility's emission points,indicating compliance with this condition at the time of this inspection. Condition A.7 contains the notification requirement of 15A NCAC 2D .0535.To comply with this condition,the facility shall notify the Director of any excess emissions that last for more than four hours and that result from any malfunction,breakdown of process or control equipment,or any other abnormal circumstance.Mr. Graybeal stated that there have been no such occurrences at the facility since the date of the last inspection and no such notifications appear to have been received at the WSRO-DAQ since the last inspection.Compliance with this condition is indicated. Condition A.8 contains the fugitive dust control requirement of 15A NCAC 2D .0540.To comply with this condition,the permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantiated complaints or excess visible emissions beyond the property boundary.No fugitive dust was observed at the time of the inspection,and there is no dust complaint history for this facility in IBEAM.Mr. Graybeal stated that no dust complaints were received by the facility itself either. Compliance with this condition is indicated. Condition A.9 contains the fabric filter requirements of 15A NCAC 2D.0611. To comply with this condition,the facility shall perform,at a minimum,an annual(for each 12-month period following the initial inspection)internal inspection of each particulate collection device system.Records of these inspections must be kept on-site. These records were provided at the time of this inspection.The records indicate that the facility complies with the manufacturer's inspection recommendations for fabric filter CD-6, which also appear to satisfy the inspection requirements in the permit.The records indicated that,on a monthly basis,all fittings are greased,and the structural stability of the duct work is inspected.On a quarterly basis,all gear oil is checked,and the fittings are greased again.On a semi-annual basis,the housing is cleaned for the rubber vanes,and all rubber vanes are replaced. On an annual basis,all internal sock filters are changed,and the doors are checked for proper sealing.The most recent monthly inspection was documented on August 5,2022,and the most recent annual internal inspection occurred on June 3,2022,at which time the rubber vanes were replaced.Compliance with this condition is indicated. Condition A.10 contains the control and prohibition of odorous emissions requirement of 15A NCAC 2D .1806.To comply with this condition,the permittee must operate the facility in such a manner as to prevent odorous emissions from causing or contributing to objectionable odors beyond the property boundary.No discernible odors were detected during the approach to the facility,and there is no history of odor complaints in IBEAM pertaining to this facility.Mr.Graybeal stated that the facility has not received any direct odor complaints either. Compliance with this condition is indicated. Condition A.12 contains the toxic air pollutant emissions limitation requirement pursuant to 15A NCAC 2Q .0711, "Emission Rates Requiring a Permit."To comply with this condition,the facility shall be operated and maintained in such a manner that emissions of any listed Toxic Air Pollutants(TAPS)from the facility,including fugitive emissions,will not exceed the Toxic Permit Emission 5 Rates(TPERs)listed in 15A NCAC 2Q.0711(a).The following table,borrowed from Permit Review R02,written by Mr.Hafner and dated February 14,2022,appears to demonstrate compliance by a significant margin.Furthermore,Mr. Graybeal indicated that production at the facility has been relatively steady,and no re-formulations appear to have occurred since these values were calculated. Compliance with this condition is indicated. Pollutant TPER Expected Actual Emissions (pounds/day)r Acetaldehde 6.81b/hr 2.61E-071b/hr Acrolein 0.02 I b/h r 3.10E-07 I b/h r Ammonia 0.68 I b/h r 0.055 I b/h r Benzene 8.1 I b/yr 0.031 I b/yr Benzo(a)pyrene 2.21b/yr 1.05E-051b/yr Chromium(VI) Soluble Chorrnate 0.013 lb/day 0 lb/day Compounds Ethyl Acetate 36 I b/h r 0.12 I b/h r Formaldehyde 0.041b/hr 5.24E-041b/hr n-Hexane 23 lb/day 0.74 lb/day MEK 22.4 I b/h r 0.004 I b/h r 78 lb/day 0.0412 lb/day MIKB 7.6 Ib/hr 0.577 Ib/hr 52 lb/day 5.77 lb/day Toluene 14.4 I b/h r 2.170 I b/h r 98 lb/day 21.70 lb/day Vinyl Chloride 26 I b/yr 2.40 I b/yr Xylene 16.4 I b/h r 0.493 I b/h r 57 lb/day 4.93 1 b/day NSPS/NESHAP Condition A.11 references the federal rules applicable to sources exempted from air permitting requirements. This states that the facility's 500-gallon capacity aboveground gasoline storage tank(IES-4)is subject to 40 CFR Part 63, Subpart CCCCCC(6C).This tank was re-located from the facility's other location(Facility ID#0500068),at which the facility's gasoline usage had been well below the 10,000 gallon per month threshold. Therefore,the facility was only subject to the work practice and recordkeeping requirements of this rule.As Mr.Graybeal and Mr.Absher stated,however,this fuel tank permanently sits in dry storage and will likely be removed from the facility.Therefore,Mr. Graybeal stated that the facility has not received any gasoline shipments since this tank was brought on-site.Therefore,the facility appears to be in compliance with the requirements of this rule. The facility's 100 kW rated capacity natural gas-fired emergency generator(I-ES-3)appears to be subject to 40 CFR Part 63 Subpart ZZZZ.As explained in Permit Review R01,written by Mr.Hafner and dated March 19,2019,there are no requirements that apply under this rule as it is currently written,due to the engine's manufacturing date of January of 2008.Nevertheless,the hour meter on this engine was checked and it read 360.5 hours at the time of this inspection,which indicates an increase of 60.8 hours since the last facility inspection on January 6,2020.Mr.Absher stated that the generator runs weekly for approximately 10 minutes for testing. Facility-Wide Emissions The following table,borrowed from the facility's most recent permit review,Permit Review R02,written by Mr.Hafner and dated February 14,2022,conveys the facility's potential and expected actual emissions. 6 Eepected Potential Emissions Potential Emissions Pollutant Actual Before Controls After Controls Emissions (tons/year) (tons/year) (tons/year) PM 0.32 13.44 1.46 PM 10 0.32 1.59 1.45 S02 0.004 0.06 0.06 NOx 0.63 10.18 10.18 CO 0.53 8.55 8.55 VOC 16.80 71.8 71.8 HAPTotai 3.33 12.6 12.6 HAPHighest(Toluene) 1 2.12 7.21 7.21 Permit Issues/Considerations The facility is planning on conducting a like-for-like replacement of permitted glue booth ES-8 and re-locating permitted glue booth ES-1 to be beside ES-8.A permit modification application was received from the facility regarding these changes on August 31,2022. This permit application was returned to the facility via a letter on September 12,2022.This letter stated that,"The replacement of glue booth(ID No.ES-8)is exempt from permitting per 15A NCAC 2Q.0 1 02(g)(1)(E)."Furthermore,"The relocation of glue booth(ID No.ES-1)does not require a permit modification because your facility has not triggered air toxics pursuant to 15A NCAC 2D .1100." Mr. Graybeal indicated that the facility is considering the possibility of routing the welding operations(I-ES-2)out to the atmosphere in the facility but would consult with permitting staff at the WSRO-DAQ prior to initiating this process. The gasoline storage tank(IES-4),which is subject to 40 CFR Part 63, Subpart CCCCCC,is in dry storage at the facility and may be removed entirely in the future. Stack Testing No stack testing has ever been performed at this facility,according to the IBEAM database. 5 Year Compliance History The facility was issued an NOV-NRE on September 23,2021,following Mr.Dyson's discovery during his PCE of the facility on September 2,2021,that woodworking equipment and a glue spray booth had been re-located from the Halcore Group,Inc.d/b/a American Emergency Vehicles,Inc.facility and were operating without being covered under the American Emergency Vehicles,Inc. -Remount Facility's Air Quality Permit.These were considered to be violations of North Carolina General Statute(NCGS) 143- 215.108,and 15A North Carolina Administrative Code(NCAC)2Q .0101.The WSRO-DAQ received a response from the facility on October 6,2021,stating that Inenco,Inc.had been contracted to prepare a permit modification application to address these issues.On November 5,2021,the facility provided a scanned copy of their permit modification application via email. The hard copy was received at the WSRO-DAQ on November 10,2021.Enforcement was not recommended in this specific case. The facility was issued an NOV on January 9,2019,for constructing and operating a dry filter paint spray booth,woodworking operation with associated bagfilter,and solvent recovery distillation unit without an Air Quality Permit.The WSRO-DAQ received an application package from this facility on January 4,2019,requesting a modification of Permit Number 10496R00. The violation was considered resolved following the acquisition of this permit application. Conclusion Based on visual observations and record review,Halcore Group,Inc.dba American Emergency Vehicles appeared to be operating in compliance with all applicable Air Quality standards and regulations at the time of this inspection. 7 NORTH CAROLINA DIVISION OF Winston-Salem Regional Office AIR QUALITY Halcore Group,Inc.dba American Emergency Vehicles Inspection Report NC Facility ID 0500075 Date: 09/14/2022 County/FIPS:Ashe/009 Facility Data Permit Data Halcore Group,Inc. dba American Emergency Vehicles Permit 10496/R02 101 AEV Lane Issued 2/14/2022 Jefferson,NC 28640 Expires 4/30/2024 Lat: 36d 25.5501m Long: 8ld 28.9002m Class/Status Small SIC: 3711 /Motor Vehicles And Car Bodies Permit Status Active NAILS: 336211 /Motor Vehicle Body Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP MACT Part 63: Subpart 6C,Subpart ZZZZ Gary Graybeal Barry DeRousse Jeff Dreyer Compliance Manager Vice President/General Process Control Manager (336)977-7203 Manager (336)846-8010 (336)846-8010 Compliance Data Comments: Inspection Date 09/08/2022 Inspector's Name Ryan Dyson Inspector's Signature: Z� DMM Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: 9/14/2022 Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP No emissions inventory on record. The emissions inventory is due 01/31/2024. *Highest HAP Emitted inpounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 09/23/2021 NOV/NRE 2Q .0101 Required Air Quality Permits 02/14/2022 01/09/2019 NOV 2Q .0 10 1 Required Air Quality Permits 03/19/2019 Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested 1 Permitted Sources Emission Emission Source Co ntrol Control System Source ID Description 7 S ystem ID Description FSpray Booths ES-2 dry filter-type paint spray booth equipped with natural gas-fired N/A N/A direct-fired burner(3.58 million Btu per hour maximum heat input rate) ES-3,ES-5 two dry filter-type paint spray booths each equipped with a natural gas- fired direct-fired burner N/A N/A (3.11 million Btu per hour maximum heat input rate) ES-4,ES-12,ES-13 three dry filter-type paint spray booths each equipped with a natural gas- N/A N/A fired direct-fired burner (3.4 million Btu per hour maximum heat input rate) Gluing Operations ES-1,ES-8 two glue booths N/A N/A ES-9,ES-10,ES-11, three glue stations N/A N/A Misc.Sources ES-6 wood working operations CD-6 fabric filter (1,830 square feet of filter area) ES-7 solvent recovery process with integral process condenser N/A N/A Insignificant/Exempt Activities Exemption Source of Source of Source Regulation TAPs? Title V 7 Pollutants? I-ES-1 -body prep areas(4 total)equipped with two(2) 2Q 0102 natural gas-fired pressure washers(0.82 million Btu per hour maximum heat input rate total) (h)(1)(B) I-ES-2-welding operations I-ES-3 -natural gas-fired emergency generator(100 kW rated capacity) [NESHAP-ZZZZ] I-ES-6-drying booth equipped with a natural gas-fired 2Q .0102 (h)(5) Yes Yes burner(2.0 million Btu per hour maximum heat input rate) IES-4-above-ground gasoline storage tank(500-gallon capacity) [NESHAP—CCCCCC] 2Q .0102 (g)(4) IES-5-above-ground diesel storage tank(500-gallon capacity) 2 Introduction On September 8,2022,Mr.Ryan Dyson,Environmental Specialist for the Winston-Salem Regional Office of the North Carolina Division of Air Quality(WSRO-DAQ),met with Mr. Gary Graybeal,Compliance Manager and Mr.Mike Absher,Maintenance Manager,for an unannounced Full Compliance Evaluation(FCE)of Halcore Group,Inc.dba American Emergency Vehicles.This facility was most recently inspected as part of a Partial Compliance Evaluation(PCE)conducted by Mr.Dyson on September 2,2021. At the time of that PCE,the facility was found to be in violation of 15A NCAC 02Q .0101,"Required Air Quality Permits,"for constructing and operating a source subject to an applicable standard,requirement,or rule that emits any regulated pollutant without obtaining an air quality permit for that equipment,and North Carolina General Statute 143-215.108,for altering or changing the construction or method of operation of any equipment or process from which air contaminants are or may be emitted,without permit coverage for that equipment and/or activity.This stemmed from the facility having re-located emission sources from their other location(Facility ID#0500068)and placing them in operation at this location without permit coverage.The facility's current permit (Permit#10496R02)was issued on February 14,2022 to incorporate these changes,as well as the additions of three new paint spray booths(ES-4,ES-12 and ES-13).Mr. Graybeal indicated that the demand for their products has never been higher,but their production is steady,as it has been somewhat limited by supply chain and staffing issues.Mr.Graybeal confirmed that the facility operates from 6:30AM to S:OOPM,Monday through Thursday,for 50 weeks per year. The facility also operates on occasional Fridays. All IBEAM contact information was confirmed by Mr.Graybeal at the time of this inspection. Safety Equipment Proper Personal Protective Equipment(PPE)for this facility includes safety shoes,hearing protection and eye protection. Applicable Regulations Permit Condition A.1 states that the facility is subject to the following regulations:Title 15A North Carolina Administrative Code (NCAC), Subchapter 2D.0202,2D .0512,2D .0515,2D .0516,2D .0521,2D.0535,2D .0540,2D .0611,2D .I I 11 (40 CFR Subparts ZZZZ and CCCCCC),2D .1806,and 2Q.0711. This facility is not subject to the Risk Management Plan(RMP)requirements of the 112(r)Program,as it does not purchase,produce,utilize,or store any of the regulated substances in quantities above their associated threshold limits. The facility is still subject to the General Duty clause in this rule. Discussion The facility refurbishes ambulances by removing the bodies of existing ambulances to remount them on new frames. Some of the ambulances also receive paint and internal cabinetry work,when desired by the customer.The process begins with the disassembly and removal of the body from the existing chassis.The rear box is then prepped for painting(if required)in the four exempt body prep areas with two natural gas-fired pressure washers(I-ES-1).One of these body prep areas appeared to be in active use,with the pressure washing of a truck body occurring at the time of this inspection.If necessary,the body and box are also sent to the exempt welding operations(I-ES-2),which were in operation at the time of this inspection.It should be noted that the welding operations at the facility do not currently exhaust out to the atmosphere.Mr.Graybeal indicated that the facility is considering the possibility of routing the welding operations out to the atmosphere in the future but would consult with permitting staff at the WSRO-DAQ prior to initiating this process. If the body and box are to be re-painted,then they are sent to the dry filter prime spray booths with natural gas fired direct burners (ES-3 and ES-5).These booths were observed on-site but did not appear to be in operation at the specific time of this inspection. Nevertheless,the filters appeared to be properly installed with no discernible gaps or holes.The facility keeps filter change records posted beside each paint spray booth.These records indicate that the exhaust blanket filters are typically changed on a weekly basis. After priming,the body and box can be painted in any of the facility's production dry filter paint spray booths with associated natural gas-fired burners(ES-2,ES-4,ES-12,or ES-13).ES-4,ES-12 and ES-13 had just completed their installation processes approximately a week before this inspection,according to Mr.Graybeal.ES-4 and ES-13 were observed in operation with no discernible visible emissions at the time of this inspection. The facility is also permitted for two glue spray booths(ES-1 and ES-8).Neither of these glue booths were observed in operation at the time of this inspection.Mr. Graybeal indicated that the facility is planning on re-locating ES-1 to be positioned beside ES-8 in the future.Furthermore,the facility is planning on replacing ES-8 with a newer,like-for-like glue booth in the future.Mr. Graybeal provided a copy of an email he had sent to Mr.Jim Hafner,Acting Permits Coordinator for the WSRO-DAQ,regarding this issue and it did not appear that a permit modification,or any modeling would be required to be conducted in the event of this replacement and re-location.Mr.Hafner appeared to cite 15A NCAC 02Q.0102(g)(1)(E)in this matter.More information pertaining to this is covered in the permit issues/considerations section of this report.The glue booths are used to glue the cabinetry and other interior pieces prior to the remounting of the box. 3 The facility also has three small glue spray stations for touch ups that don't exhaust to the atmosphere(ES-9,ES-10 and ES-11).A water-based glue(3M Fastbond Foam Adhesive 100NF)is used exclusively in these three small stations.Mr. Graybeal indicated that the facility may consider routing these three small stations to the atmosphere in the future,and that is why they requested that they be permitted. The facility's woodworking equipment(ES-6)was observed in operation at the time of this inspection. These woodworking operations appear to consist of multiple table saws and two CNC routers.The emissions from the woodworking operations(ES-6)are controlled by a fabric filter(CD-6),which was also observed in operation with no discernible visible emissions at the time of this inspection.The facility is also permitted for a solvent recovery process with an integral process condenser(ES-7). This equipment had been used to recover MEK.However,this unit is currently disconnected.Mr. Graybeal indicated that the facility was informed by insurance personnel that they should construct a separate building outside of the main facility to house this unit,and the facility decided it did not appear cost-effective to do so.Mr. Graybeal indicated there are currently no plans to bring this unit back online.The most recent permit issuance also covered the addition of three exempt sources,including a 500-gallon aboveground gasoline storage tank(IES-4), a 500-gallon aboveground diesel storage tank(IES-5)and a drying booth equipped with a natural gas-fired burner(I-ES-6).The two storage tanks(IES-4 and IES-5)were brought over from facility ID#0500068.Mr.Graybeal indicated that these two tanks sit in dry storage in a shed on the property and will likely never be placed in service at the facility.Mr.Absher indicated that the facility may be in the process of removing these tanks altogether.The drying booth(I-ES-6)is a new installation. It was observed on-site,but Mr. Graybeal indicated it hasn't yet been placed in operation.Lastly,the facility's 100 kW rated capacity natural gas-fired emergency generator was also observed on-site. This generator was not in operation,and its hour meter read 360.5 hours at the time of this inspection. Permit Conditions Condition A.2 contains the permit renewal and emission inventory requirement of 15A NCAC 2D.0202. To meet this requirement, the facility must submit a permit renewal request and air pollution emission inventory report for the 2022 calendar year at least 90 days prior to the expiration date of the permit. The current permit for this facility expires April 30,2024. This condition was discussed with Mr. Graybeal at the time of inspection and future compliance is anticipated. Condition A.3 contains the particulate control requirement of 15A NCAC 2D.0512,"Particulates from Wood Products Finishing Plants."To comply with this condition,the facility must not discharge particulate matter stemming from the working,sanding,or finishing of wood without providing for its collection,adequate duct work and properly designed collectors.All ductwork at the facility appeared to be properly constructed and maintained,and records were provided to Mr.Dyson at the time of inspection to demonstrate that inspections and maintenance of the fabric filter unit are occurring in a timely manner,as described below. Compliance with this condition is indicated. Condition AA contains the particulate control requirement of 15A NCAC 2D.0515.To comply with this condition,the particulate matter emissions from the emission sources at this facility must not exceed allowable emission rates,as derived from the following equations,where P is the process throughput rate in tons per hour(tons/hr.)and E is the allowable emission rate in pounds per hour (lbs./hr.). E=4.10 * (P)0" for P<=30 tons/hr.,or E=55 * (P)0`1-40 for P>30 tons/hr. The following table,compiled from the facility's permit reviews,demonstrates that the anticipated controlled emission rates are less than the allowable emission rates.Compliance with this condition is indicated. Process Weight Rate(P) Allowable Emission Rate Anticipated Controlled Emission Source(ID No.) [tons/hr.] (E) [lb.PM/hr.] Emission Rate [lb. PM/hr.] Glue Spray Booth(ES-1) F 0.0135 0.229 0.00 Dry Filter Paint Spray Booth(ES-2) 0.0135 0.229 0.0233 Dry Filter Prime Spray Booth(ES-3) F 0.0135 0.229 0.0233 Body Prep Areas(I-ES-1) 0.000125 0.0099 0.00608 4 Process Weight Rate(P) Allowable Emission Rate r nticipated Controlled Emission Source(ID No.) [tons/hr.] (E) [lb.PM/hr.] Emission Rate [lb. PM/hr.] Welding Operations(I-ES-2) 0.000185 0.0129 0.00285 Dry Filter Paint Spray Booth(ES-4) 0.00044 0.0217 0.0131 Dry Filter Prime Spray Booth(ES-5) 0.00044 0.0217 0.0131 Dry Filter Paint Spray Booth(ES-12) 0.00465 0.112 0.06 Dry Filter Prime Spray Booth(ES-13) 0.00465 0.112 0.06 Condition A.5 contains the sulfur dioxide control requirement of 15A NCAC 2D.0516. To comply with this condition,sulfur dioxide emissions from the facility's combustion sources must not exceed 2.3 pounds per million Btu heat input.According to the facility's most recent Permit Review,R02,written by Mr.Hafner and dated February 14,2022,the actual sulfur dioxide emissions from the natural gas-fired burners are calculated to be 0.0006 lb./MMBtu.Compliance with this condition is indicated. Condition A.6 contains the visible emissions control requirement of 15A NCAC 2D .0521.To comply,visible emissions from emission sources manufactured after July 1, 1971,shall not exceed 20 percent opacity when averaged over a six-minute period,except that six-minute periods averaging not more than 87 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour period.No visible emissions were observed from any of the facility's emission points,indicating compliance with this condition at the time of this inspection. Condition A.7 contains the notification requirement of 15A NCAC 2D .0535.To comply with this condition,the facility shall notify the Director of any excess emissions that last for more than four hours and that result from any malfunction,breakdown of process or control equipment,or any other abnormal circumstance.Mr. Graybeal stated that there have been no such occurrences at the facility since the date of the last inspection and no such notifications appear to have been received at the WSRO-DAQ since the last inspection.Compliance with this condition is indicated. Condition A.8 contains the fugitive dust control requirement of 15A NCAC 2D .0540.To comply with this condition,the permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantiated complaints or excess visible emissions beyond the property boundary.No fugitive dust was observed at the time of the inspection,and there is no dust complaint history for this facility in IBEAM.Mr. Graybeal stated that no dust complaints were received by the facility itself either. Compliance with this condition is indicated. Condition A.9 contains the fabric filter requirements of 15A NCAC 2D.0611. To comply with this condition,the facility shall perform,at a minimum,an annual(for each 12-month period following the initial inspection)internal inspection of each particulate collection device system.Records of these inspections must be kept on-site. These records were provided at the time of this inspection.The records indicate that the facility complies with the manufacturer's inspection recommendations for fabric filter CD-6, which also appear to satisfy the inspection requirements in the permit.The records indicated that,on a monthly basis,all fittings are greased,and the structural stability of the duct work is inspected.On a quarterly basis,all gear oil is checked,and the fittings are greased again.On a semi-annual basis,the housing is cleaned for the rubber vanes,and all rubber vanes are replaced. On an annual basis,all internal sock filters are changed,and the doors are checked for proper sealing.The most recent monthly inspection was documented on August 5,2022,and the most recent annual internal inspection occurred on June 3,2022,at which time the rubber vanes were replaced.Compliance with this condition is indicated. Condition A.10 contains the control and prohibition of odorous emissions requirement of 15A NCAC 2D .1806.To comply with this condition,the permittee must operate the facility in such a manner as to prevent odorous emissions from causing or contributing to objectionable odors beyond the property boundary.No discernible odors were detected during the approach to the facility,and there is no history of odor complaints in IBEAM pertaining to this facility.Mr.Graybeal stated that the facility has not received any direct odor complaints either. Compliance with this condition is indicated. Condition A.12 contains the toxic air pollutant emissions limitation requirement pursuant to 15A NCAC 2Q .0711, "Emission Rates Requiring a Permit."To comply with this condition,the facility shall be operated and maintained in such a manner that emissions of any listed Toxic Air Pollutants(TAPS)from the facility,including fugitive emissions,will not exceed the Toxic Permit Emission 5 Rates(TPERs)listed in 15A NCAC 2Q.0711(a).The following table,borrowed from Permit Review R02,written by Mr.Hafner and dated February 14,2022,appears to demonstrate compliance by a significant margin.Furthermore,Mr. Graybeal indicated that production at the facility has been relatively steady,and no re-formulations appear to have occurred since these values were calculated. Compliance with this condition is indicated. Pollutant TPER Expected Actual Emissions (pounds/day)r Acetaldehde 6.81b/hr 2.61E-071b/hr Acrolein 0.02 I b/h r 3.10E-07 I b/h r Ammonia 0.68 I b/h r 0.055 I b/h r Benzene 8.1 I b/yr 0.031 I b/yr Benzo(a)pyrene 2.21b/yr 1.05E-051b/yr Chromium(VI) Soluble Chorrnate 0.013 lb/day 0 lb/day Compounds Ethyl Acetate 36 I b/h r 0.12 I b/h r Formaldehyde 0.041b/hr 5.24E-041b/hr n-Hexane 23 lb/day 0.74 lb/day MEK 22.4 I b/h r 0.004 I b/h r 78 lb/day 0.0412 lb/day MIKB 7.6 Ib/hr 0.577 Ib/hr 52 lb/day 5.77 lb/day Toluene 14.4 I b/h r 2.170 I b/h r 98 lb/day 21.70 lb/day Vinyl Chloride 26 I b/yr 2.40 I b/yr Xylene 16.4 I b/h r 0.493 I b/h r 57 lb/day 4.93 1 b/day NSPS/NESHAP Condition A.11 references the federal rules applicable to sources exempted from air permitting requirements. This states that the facility's 500-gallon capacity aboveground gasoline storage tank(IES-4)is subject to 40 CFR Part 63, Subpart CCCCCC(6C).This tank was re-located from the facility's other location(Facility ID#0500068),at which the facility's gasoline usage had been well below the 10,000 gallon per month threshold. Therefore,the facility was only subject to the work practice and recordkeeping requirements of this rule.As Mr.Graybeal and Mr.Absher stated,however,this fuel tank permanently sits in dry storage and will likely be removed from the facility.Therefore,Mr. Graybeal stated that the facility has not received any gasoline shipments since this tank was brought on-site.Therefore,the facility appears to be in compliance with the requirements of this rule. The facility's 100 kW rated capacity natural gas-fired emergency generator(I-ES-3)appears to be subject to 40 CFR Part 63 Subpart ZZZZ.As explained in Permit Review R01,written by Mr.Hafner and dated March 19,2019,there are no requirements that apply under this rule as it is currently written,due to the engine's manufacturing date of January of 2008.Nevertheless,the hour meter on this engine was checked and it read 360.5 hours at the time of this inspection,which indicates an increase of 60.8 hours since the last facility inspection on January 6,2020.Mr.Absher stated that the generator runs weekly for approximately 10 minutes for testing. Facility-Wide Emissions The following table,borrowed from the facility's most recent permit review,Permit Review R02,written by Mr.Hafner and dated February 14,2022,conveys the facility's potential and expected actual emissions. 6 Eepected Potential Emissions Potential Emissions Pollutant Actual Before Controls After Controls Emissions (tons/year) (tons/year) (tons/year) PM 0.32 13.44 1.46 PM 10 0.32 1.59 1.45 S02 0.004 0.06 0.06 NOx 0.63 10.18 10.18 CO 0.53 8.55 8.55 VOC 16.80 71.8 71.8 HAPTotai 3.33 12.6 12.6 HAPHighest(Toluene) 1 2.12 7.21 7.21 Permit Issues/Considerations The facility is planning on conducting a like-for-like replacement of permitted glue booth ES-8 and re-locating permitted glue booth ES-1 to be beside ES-8.A permit modification application was received from the facility regarding these changes on August 31,2022. This permit application was returned to the facility via a letter on September 12,2022.This letter stated that,"The replacement of glue booth(ID No.ES-8)is exempt from permitting per 15A NCAC 2Q.0 1 02(g)(1)(E)."Furthermore,"The relocation of glue booth(ID No.ES-1)does not require a permit modification because your facility has not triggered air toxics pursuant to 15A NCAC 2D .1100." Mr. Graybeal indicated that the facility is considering the possibility of routing the welding operations(I-ES-2)out to the atmosphere in the facility but would consult with permitting staff at the WSRO-DAQ prior to initiating this process. The gasoline storage tank(IES-4),which is subject to 40 CFR Part 63, Subpart CCCCCC,is in dry storage at the facility and may be removed entirely in the future. Stack Testing No stack testing has ever been performed at this facility,according to the IBEAM database. 5 Year Compliance History The facility was issued an NOV-NRE on September 23,2021,following Mr.Dyson's discovery during his PCE of the facility on September 2,2021,that woodworking equipment and a glue spray booth had been re-located from the Halcore Group,Inc.d/b/a American Emergency Vehicles,Inc.facility and were operating without being covered under the American Emergency Vehicles,Inc. -Remount Facility's Air Quality Permit.These were considered to be violations of North Carolina General Statute(NCGS) 143- 215.108,and 15A North Carolina Administrative Code(NCAC)2Q .0101.The WSRO-DAQ received a response from the facility on October 6,2021,stating that Inenco,Inc.had been contracted to prepare a permit modification application to address these issues.On November 5,2021,the facility provided a scanned copy of their permit modification application via email. The hard copy was received at the WSRO-DAQ on November 10,2021.Enforcement was not recommended in this specific case. The facility was issued an NOV on January 9,2019,for constructing and operating a dry filter paint spray booth,woodworking operation with associated bagfilter,and solvent recovery distillation unit without an Air Quality Permit.The WSRO-DAQ received an application package from this facility on January 4,2019,requesting a modification of Permit Number 10496R00. The violation was considered resolved following the acquisition of this permit application. Conclusion Based on visual observations and record review,Halcore Group,Inc.dba American Emergency Vehicles appeared to be operating in compliance with all applicable Air Quality standards and regulations at the time of this inspection. 7