AQ_F_0200098_20220511_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Piedmont Composites and Tooling,LLC
NC Facility ID 0200098
Inspection Report County/FIPS:Alexander/003
Date: 05/11/2022
Facility Data Permit Data
Piedmont Composites and Tooling,LLC Permit 09941 /T04
33 Lewittes Road Issued 4/2/2019
Taylorsville,NC 28681 Expires 3/31/2024
Lat: 35d 55.0386m Long: 8ld 8.6994m Class/Status Title V
SIC: 3089/Plastics Products,Nee Permit Status Active
NAICS: 326121 /Unlaminated Plastics Profile Shape Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Haley Millsaps David Himebaugh Paul Zawila MACT Part 63: Subpart WWWW
President Senior Environmental
[phone] Engineer
[phone]
Compliance Data
Comments:
Inspection Date 05/11/2022
Inspector's Name Karyn Kurek
Inspector's Signature: 1`�.�f.ff Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature:May 11,2022 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2020 0.3900 --- --- 12.64 --- 0.1900 15052.23
2019 0.4500 --- --- 13.47 --- 0.2300 16464.36
2018 0.5700 --- --- 16.34 --- 0.2800 20656.06
*Highest HAP Emitted(in pounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
01/04/2019 NOV/NRE 2D.1111 Maximum Achievable Control Technology 09/27/2019
03/26/2018 NOV 2D.I I I I Maximum Achievable Control Technology 05/04/2018
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

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Type X Full Compliance _Partial Compliance _Complaint Other:
Action: Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 05/11/2022 _IBEAM WARNING/OB,NOD,NOV,NRE
Tracking: X IBEAM Document
X IBEAM Inspection,list date inspected X IBEAM LAT/LONG,Facility Locked
X IBEAM Inspection, list date draft is submitted X IBEAM LAT/LONG,Coordinates checked
X IBEAM Inspection,pollutants/programs IBEAM Complaint
checked X IBEAM Planning,Next Inspection Date
05/01/2023
Directions: From Statesville,take exit 148 on I-40 West and turn right. Follow Hwy. 64 North to
Adam's Pond Lane. Turn right onto Adam's Pond Lane. Turn left onto Highway 90. Facility is less than
half a mile on right(old Kincaid furniture plant with water tank).
Safety Equipment: Safety shoes and safety glasses are recommended.
Safety Issues: The inspector of this facility should bring a co-inspector due to confrontations
encountered with Mr. Himegaugh during a previous inspection.
Coordinates: A review of the facility's coordinates on DAQ's "Facilities Regulated by Air Quality"
website indicates the facility latitude and longitude coordinates are not listed,however the location appears
to be accurate. No changes to the latitude and longitude coordinates of this facility in IBEAM are needed.
Latitude and longitude coordinates of this facility are locked in IBEAM.
Email Contacts: Facility contacts were reviewed no changes were needed.
1. General Information. The purpose of this site visit was to conduct a routine air quality inspection. This
facility manufactures fiberglass church steeples, baptisteries, and a small number of specialized
fiberglass components for car dealership signs, boat parts, water slides, campers, and hospital clean
rooms. In addition to production areas,the facility utilizes space for storage of either molds or finished
product. The plant operates 10 hours per day, four days of the week(Monday through Thursday)with
occasional Friday shifts. The mailing address for this facility is 33 Lewittes Road, Taylorsville, NC,
28681.
1 arrived at the facility at approximately 11 AM on Wednesday,May 11,2022 and met with Mr.David
Himebaugh, President,who accompanied me during the inspection and records review.
2. File Review.
A. Contacts. Facility contacts were reviewed.No changes were needed.
B. Files. The following files were reviewed prior to the inspection: previous inspection reports;
correspondence since the last inspection; semiannual, and annual reports, complaints, annual
emissions inventories, etc.

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C. Compliance history.
The facility was issued an NOV/NRE on January 4, 2019 for failure to monitor and keep records
of gallons of HAP coatings used as required to avoid applicability of 15A NCAC 2D .1111.A civil
penalty was assessed in the amount of $4,542.00 and later reduced through the formal EMC
process.
The facility was issued an NOV on March 26, 2018 for failure to monitor and keep records of
gallons of HAP coatings used as required to avoid applicability of 15A NCAC 2D .1111.
The facility was issued an NOD on July 24, 2013 for failure to keep records of monthly usage of
HAP coatings as required to avoid applicability of 15A NCAC 2D .1111 (40 CFR 63, Subpart
PPPP,NESHAP for Surface coating of plastic Parts and Products).
The facility was issued an NOV on September 9, 2013 for construction and operation prior to
obtaining an Air Quality Permit for the sanding operation for fiberglass wall panels with
associated bagfilter.
D. Operating Conditions established by Stack Testing.—N/A.
E. Records Required by Title V. During this inspection, all records required by the Title V permit
were reviewed. The records appear to be in compliance,based on information submitted.
F. NSPS/NESHAP Review
The facility is subject to NESHAP Subpart WWWW — NESHAP for Reinforced Plastics
Composites Production. Compliance with this MACT is discussed below.
The facility also has an avoidance condition in the permit for NESHAP Subpart PPPP — Surface
Coating of Plastic Parts and Products. Compliance with this avoidance condition is discussed
below.
There are two inactive boilers that are abandoned in place. The boilers were used by the previous
owner of the building. There are no emergency generators at the facility. Therefore,NESHAP 4Z
and 6J do not apply.
The facility does not have any gasoline storage tanks onsite; therefore, is not subject to NESHAP
6C.
4. Part I-AIR QUALITY TITLE V OPERATION PERMIT. The following permitted emission sources
and/or control devices listed in Section 2 Paragraph 2.1-Emission Source(s) and Control Devices(s)
Specific Limitations and Conditions were observed during this inspection:

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A.
Emission Source Control Control Device
ID No. Emission Source Description Device Description
ID No.
002 Laminating/gel coat operation N/A N/A
MACT WWWW
006 Resin storage tank(5,880 gallons) N/A N/A
MACT WWWW
The laminating and gel coat operations are located in different areas of the plant. Gel coating is
typically performed early in the morning. The facility also has an area for closed molding
operations. Loss of styrene emissions from closed molding is approximately 1%while loss of
styrene from open molding is approximately 17%. The resin tank is located outside the building.
Observed. The gel coat area and the laminating area were not in operation at the time of
inspection. The resin storage tank has been empty since September 2020 when it was cleaned.
The storage tank is disconnected and no longer in use.
1. 15A NCAC 2D .0521: Control of Visible Emissions-
Visible emissions from each source shall not be more than 20 percent opacity when averaged
over a six-minute period. No monitoring/recordkeeping/reporting is required.
Observed. No visible emissions were observed during the time of inspection. The facility is
performing monthly visible emission although not required. The most recent observation
occurred May 9, 2022. Compliance with this stipulation is indicated.
2. 15A NCAC 2D .1111: Maximum Achievable Control Technology
The Permittee shall comply with all applicable provisions contained in Environmental
Management Commission Standard 15A NCAC 2D .1111, "Maximum Achievable Control
Technology" (MACT) as promulgated in 40 CFR 63, Subpart WWWW, "National Emission
Standards for Hazardous Air Pollutants for Reinforced Plastic Composites Production,"
including Subpart A "General Provisions" as follows:
The Permittee shall limit its organic hazardous air pollutant (HAP) emissions from its open
molding,gel-coating operations(ID No. 002)as described in 63.5805(b)and Table 3 -Subpart
WWWW,which include,in part:

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If your operation And you use... Your organic HAP
is... emissions limit is...
Open molding—non- Mechanical resin application 88 (lb/ton)
corrosion-resistant Filament application 188 (lb/ton)
and/or high strength Manual resin application 87 (lb/ton)
Open molding— Mechanical resin application 254(lb/ton)
tooling Manual resin application 157 (lb/ton)
Open molding—gel Tooling gel coating 440(lb/ton)
coat White/off white pigmented gel 267 (lb/ton)
coating 377 (lb/ton)
All other pigmented gel coating 522 (lb/ton)
Clear production gel coat
As specified in 40 CFR 63.5805(b),the Permittee must meet all applicable work practice
standards in Table 4 of MACT Subpart WWWW, including:
For... You must...
All cleaning operations Not use cleaning solvents that contain HAP, except
that styrene may be used as a cleaner in closed
systems, and organic HAP containing cleaners may be
used to clean cured resin from application equipment.
Application equipment includes any equipment that
directly contacts resin.
All HAP-containing materials Keep containers that store HAP-containing materials
storage operations closed or covered except during the addition or
removal of materials. Bulk HAP-containing materials
storage tanks may be vented as necessary for safety.
All mixing operations Use mixer covers with no visible gaps present in the
mixing covers, except that gaps of up to one inch are
permissible around the mixer shafts and any required
instrumentation.
Keep the mixer covers closed while actual mixing is
occurring except when adding materials or changing
covers to the mixing vessels.
The Permittee shall demonstrate that, on average, the individual organic HAP emission limits
for each unique combination of operation type and resin application method or gel coat type
are met. If all emission factors are equal to or less than their corresponding emission limits,
then the Permittee is in compliance. The results of the monitoring shall be maintained in a
logbook on-site and made available to an authorized representative upon request. Summary
reports are required to be submitted semi-annually.
Observed.The facility contracts with Value Environmental to maintain monthly emission logs
for compliance with this MACT. As shown in the table below, the facility demonstrates
compliance with this MACT on a monthly basis by determining a styrene weighted average for
all resins/gelcoats used (based on the emission factors listed in the table above) and then
determines the average styrene emissions based on materials purchased. To comply with the
requirement that prohibits the use of HAP containing solvents, the facility uses acetone as a
cleaning solvent.

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The monthly logs were observed from April 2021 through April 2022. Semi-annual reports
were received on July 22,2021 and January 27,2022 as required. During inspection,VOC
containing materials were properly stored and covered. Compliance with this stipulation is
indicated.
Previous Inspection
Month Allowable Styrene Weighted Styrene
Content Average
lb/ton lb/ton
Dec 2019 152.5 129.1
Jan 2020 151.2 127.9
Feb 2020 149.7 126.7
Mar 2020 157.1 133.3
A r 2020 152.2 128.8
May 2020 160.1 135.9
June 2020 173.3 148.1
July 2020 172.1 147.1
Aug 2020 179.4 154.1
Sept 2020 174.2 149.8
Oct 2020 168.7 144.8
Nov 2020 184.1 159.5
Dec 2020 181.0 156.7
Jan 2021 178.7 154.5
Feb 2021 191.4 166.9
Mar 2021 178.9 156.1
Current Inspection
April 2021 181.1 158.0
May 2021 181.3 157.5
June 2021 176.1 153.1
July 2021 173.9 150.7
August 2021 176.8 153.6
September 2021 176.2 152.9
October 2021 178.4 155.2
November 2021 176.7 153.7
December 2021 176.0 152.9
January 2022 179.8 155.6
February 2022 181.1 156.6
March 2022 184.4 159.3
April 2022 184.6 159.3

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B.
Emission Control
Source Emission Source Description Device Control Device
ID No. ID No. Description
004 Dry filter-type surface coating N/A N/A
operation
Observed. The paint booths (2) were not operating at the time of inspection. The dry filters
appeared to be well maintained and in proper place.
1. 15A NCAC 2D .0515: Particulates from Miscellaneous Industrial Processes
Emissions of particulate matter from this source (ID No. 004) shall not exceed an allowable
emission rates. The facility is required to perform monthly visual inspections of the dry filter,
and an annual (for each 12-month period following the initial inspection) inspection of the
associated ductwork noting the structural integrity.
The results of inspection and maintenance shall be maintained in a log. The log shall record
the following: the date and time of each recorded action; the results of each inspection; the
results of any maintenance performed on the dry filter, and any variance from manufacturer's
recommendations, if any, and corrections made. No reporting is required.
Observed. Records of the monthly visual inspections of the dry filter were observed from May
2021 through May 2022. The inspection sheets indicate they do inspect the structural integrity
of the ductwork on a monthly basis even though this is required annually. The most recent
inspection was performed May 9, 2022. Compliance with this stipulation is indicated.
2. 15A NCAC 2D .0521: Control of Visible Emissions
Visible emissions shall not be more than 20 percent opacity when averaged over a six-minute
period. To assure compliance, once a month the Permittee shall observe the emission point(s)
of this source(ID No. 004) for any visible emissions above normal. The monthly observation
must be made for each month of the calendar year period to ensure compliance with this
requirement.
The results of inspection and maintenance shall be maintained in a log. Summary reports are
required to be submitted semi-annually.
Observed. Monthly visible emission observations were performed,and records were reviewed
from May 2021 through May 2022. The most recent observation occurred May 9,2022. These
records indicated no deviations occurred. Semi-annual reports were received on July 22,2021
and January 27,2022 as required. Compliance with this stipulation is indicated.
3. 15A NCAC 2Q.0317:NESHAP Avoidance Condition for Surface Coating of Plastic Parts
and Products (40 CFR 63, Subpart PPPP)
In order to avoid applicability of this rule,the facility is limited to using less than 100 gallons
of HAP coatings per consecutive 12-month period to coat plastic parts or products.

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The facility is required to keep records of gallons of HAP coatings that are used to coat plastic
parts or products on a monthly basis. Summary reports are required to be submitted semi-
annually.
Observed. The monthly logs were observed from May 2021 through April 2022. The table
below shows the monthly usage and 12-month totals for HAP containing coatings. The
coatings are mostly used for water slides. Semi-annual reports were received on July 22,2021
and January 27,2022 as required. Compliance with this stipulation is indicated.
Previous Ins ectio = Current Inspection
Month Monthly 12-Month Month Monthly 12-Month
Usage Total Usage Total
(gals) (gals) (gals) (gal)
Dec 2019 0 25 Aril 2021 0 0
Jan 2020 0 25 May 2021 0 0
Feb 2020 0 25 June 2021 3 3
Mar 2020 0 25 July 2021 0 3
Apr 2020 0 25 August 0 3
2021
May 2020 0 25 Sept. 2021 0 3
June 2020 0 25 Oct. 2021 0 3
July 2020 0 25 Nov. 2021 0 3
Aug2020 0 20 Dec. 2021 0 3
Sept 2020 0 20 Jan. 2022 0 3
Oct 2020 0 15 Feb. 2022 0 3
Nov 2020 0 0 March 0 3
2022
Dec 2020 0 0 A ril 2022 1.5 5
Jan 2021 0 0
Feb 2021 0 0
Mar 2021 0 0
C.
Emission Source Control Device
ID No. Emission Source Description ID No Control Device Description
005 Sanding Operations DC001 Dust Collector(800 square
feet of filter area)
Observed. The sanding operation and associated dust collector(DC001) were removed from the
facility March 4, 2020. It was mostly used for sanding edges of boards used for hospital clean
rooms.
1. 15A NCAC 21) .0515: Particulates from Miscellaneous Industrial Processes
Emissions of particulate matter from this source (ID No. 005) shall not exceed an allowable
emission rates. The facility is required to perform monthly visual inspections of the filters,
system ductwork, and material collection unit. An annual internal (for each 12-month period

Piedmont Composites and Tooling, LLC
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following the initial inspection) inspection is required for the dust collector. The results of
inspection and maintenance shall be maintained in a log. No reporting is required.
Observed. The sanding operation and associated dust collector (DC001) was removed from
the facility March 4,2020. Monthly visual inspections are still being conducted and recorded
indicating they have been removed. Records of the monthly visual inspections of the filter and
ductwork were observed from December 2019 through April 2021. Previous annual
inspections were done on December 11, 2019, January 8, 2019 and January 18, 2018. The
most recent monthly inspection was performed January 13, 2020 and the unit was removed
from operation March 4,2020. Compliance with this stipulation is indicated.
2. 15A NCAC 2D.0521: Control of Visible Emissions
Visible emissions shall not be more than 20 percent opacity when averaged over a six-minute
period. To assure compliance,once a month the Permittee shall observe the emission point(s)
of this source(ID No. 005) for any visible emissions above normal. The monthly observation
must be made for each month of the calendar year period to ensure compliance with this
requirement. The results of monitoring shall be maintained in a log book. Summary reports
are required to be submitted semi-annually.
Observed. Monthly visible emission observations were performed, and records were
reviewed from May 2021 through May 2022. The most recent observation occurred May 9,
2022. Semi-annual reports were received on July 22, 2021 and January 27, 2022 as required.
Compliance with this stipulation is indicated.
5. Part I-AIR QUALITY TITLE V OPERATION PERMIT. The following permitted emission sources
and/or control devices listed in Section 2 Paragraph 2.2- Multiple Emission Source(s) Specific
Limitations and Conditions were observed during this inspection:
A. Facility-Wide
1. Toxic Air Pollutant Emission Limitations and Reporting Requirements
Pursuant to 15A NCAC 02Q.0711 "Emission Rates Requiring a Permit,"for each of the below
listed toxic air pollutants(TAPS),the Permittee has made a demonstration that actual emissions
do not exceed the Toxic Permit Emission Rates(TPERs)listed in 15A NCAC 02Q .0711. The
facility shall be operated and maintained in such a manner that emissions of any listed TAPS
from the facility, including fugitive emissions, will not exceed TPERs listed in 15A NCAC
02Q .0711.
In accordance with the approved application, the Permittee shall maintain records of
operational information demonstrating that the TAP emissions do not exceed the TPERs for
ethyl acetate,methyl ethyl ketone,methyl isobutyl ketone,n-hexane,toluene, and xylene.

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ITERs Limitations
Ndlutunt(CAS Number) Carelnogens Chronic Toxicants Acute Systeaaic Acute
WYr) (lblday) Toxicants(16fhr) Irritauts
Ublhr)
cthyl acetate 16
141-78-6
methyl ethyl ketone 78 22.4
methyl isobutyl k etwc 52 7.6
(108-10-1)
n-hexane 23
110-54-3)
Toluene 98 14.4
108-88-3
X}IMC 57 16.4
(1330�20-7)
Observed. The facility maintains records of the TAPS that are also categorized as HA-Ps(not
ethyl acetate and MEK) through the monthly recordkeeping requirements for MACT Subpart
WWWW and for avoidance to MACT Subpart PPPP. The ethyl acetate and MEK are tracked
and reported in the EI. Compliance with the TPER limits were verified in the review of the
2020 emissions inventory. Compliance with this stipulation is indicated.
2. 15A NCAC 2D .1100: Control of Toxic Air Pollutant Emissions
Pursuant to 15A NCAC 2D .1100 and in accordance with the approved application for an air
toxic compliance demonstration,the following permit limits shall not be exceeded:
Pollutant Emission Source(s) Allowable Emission
Rate
styrene facility-wide 39.2lb/hr
The facility is required to maintain a logbook that records the facility-wide hourly styrene
emissions. The hourly rate is determined and recorded on a monthly basis. The facility is also
required to report semi-annually the single highest facility-wide hourly emission rate for
styrene for the previous six months
Observed. Facility-wide hourly styrene emission rates are determined from the monthly logs
required for MACT Subpart WWWW. Once the monthly records are compiled, the facility
divides the monthly styrene emissions by the number of hours worked during the month. Semi-
annual reports were received on July 22, 2021 and January 27, 2022 as required. The semi-
annual report received January 27,2022 indicated that the highest facility-wide hourly emission
rate for styrene was 14.4 pounds per hour. Compliance with this stipulation is indicated.
3. 15A NCAC 2D .1806: Control and Prohibition of Odorous Emissions
The Permittee shall not operate the facility without implementing management practices or
installing and operating odor control equipment sufficient to prevent odorous emissions from
the facility from causing or contributing to objectionable odors beyond the facility's boundary.
Observed. No odors were detected outside the property boundaries. Compliance with this
stipulation is indicated.

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6. Part I-AIR QUALITY TITLE V OPERATION PERMIT. Section 3 -GENERAL CONDITIONS
A. Permit. Maintain a copy of the permit and application at the facility. Observed. The permit and
application are at the facility.
B. Submissions. Except as otherwise specified, two copies of all documents, reports, test data,
monitoring data are required to be submitted to MRO. Observed. The company has been
complying with this requirement.
C. Circumvention. Operate and maintain the facility at all times in a manner that will affect an overall
reduction in air pollution. Observed. The company has been complying with this requirement.
D. Excess Emissions. Report excess emissions and permit deviations as required. Observed. No
excess emissions have occurred to date.
E. Retention of Records. The Permittee shall retain records of all required monitoring data and
supporting information for a period of at least five years from the date of the monitoring sample,
measurement,report, or application. Observed. Records are being retained.
F. Compliance Certification. By March I", submit a compliance certification (for the preceding
calendar year). Observed. The ACC was received on January 25,2022. Compliance is indicated.
G. Emissions Inventory. Submit an emissions inventory by June 30 of each year. Observed. The
facility has been complying with this requirement. The most recent EI for calendar year 2020 was
received June 16, 2021. The Emission Inventory report for 2021 is not due until June 30, 2022.
Compliance is indicated.
H. Refrigerant Requirements (Stratospheric Ozone and Climate Protection). Dispose of refrigerants
properly. Observed. The facility complies with this requirement by using a certified outside
contractor.
1. Section 112(r). This facility appears does not appear to be subject to the requirements of the
Chemical Accident Release Prevention Program, Section 112(r)of the Clean Air Act.
7. The following non-permitted air emission sources and control devices were observed as follows:
A. Grinding Area(ID No. IES-01)
Observed. The grinding area, also identified as the trim room, is located in a separate room.
Particulate emissions are collected by an air filtration system that vents back into the room. This
was not observed at the time of inspection.
B. Woodworking Operations(ID No. IES-02)
Observed. This was not observed at the time of inspection. This is used to make molds for casting.
Particulate emissions are collected by an air filtration system that vents back into the room.

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Page 12
C. Welding Operations(ID No. IES-03)
Observed. This was not observed at the time of inspection. The welding operations is located
inside the facility.
D. Solvent cleaning operation(ID No. IES-04)
Observed. The facility uses acetone as a cleaning solvent. The facility has a reclamation unit for
recycling acetone.
E. natural gas-fired make-up heaters(ID No. IES-08)
Observed. These heaters were not observed at the time of inspection.
8. Other compliance requirements and issues:
None.
9. Compliance Assistance.
The facility currently uses compressed air during the gel coating process to spray the materials into the
molds, however they are considering moving to a nitrogen and heat application which should reduce
emissions. I informed Mr. Himebaugh to submit a permit applicability determination request to our
office for this process change.
10. Findings.
Based on my observations, this facility appeared to be in compliance with the applicable air quality
regulations at the time of the inspection.
KAK:lms
c: MRO File
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