AQ_F_1300029_20220816_CMPL_CmpltRpt

Complaint Investigation Report County: Cabarrus
Region: MRO
NC Dept. of Environmental Quality Suspect: Galvan Industries, Inc.
Division of Air Quality Facility ID# 1300029
Record N 24764
Regional Investigator: Cook, Donna Suspect: Galvan Industries,Inc.
Regional Co-investigator: Suspect Contact: Harshad Londhe
Partner Agency: Physical Location: 7320 Galvan Way-Harrisburg
Date Complaint Received: 08/09/2022 Mailing Address: Post Office Box 369
Received By: Hayes, Denise City/State/Zip: Harrisburg NC 28075
Date assigned: 08/09/2022 Telephone: [phone]
Alternate Telephone:
Investigation date: 08/11/2022 &08/12/2022 Complainant: Bonita Pickett
Follow-up date: 08/12/2022 Complainant Address: 12034 University City Blvd
Bonita Travels
Report submit date: 08/16/2022 City/State/Zip: Charlotte NC 28213
Telephone(H): [phone]
Complaint type: DUST Telephone(W): [phone]
Complaint description: Dust/smoke from the facility Call Back Required? No Response Requested
observed at night.
Referral to DAQ: Previous DAQ contact
Situation Dangerous: Violation documented:
Occurring Now: NCFS Permit:
Type _Full Compliance _Partial Compliance X Complaint Other:
Action: Evaluation Evaluation/Reinspection Investigation
Data X Date submitted for initial review 08/16/2022 — IBEAM WARNING/OB,NOD,NOV,NRE
Tracking: —IBEAM Document
—IBEAM Inspection,list date inspected —IBEAM LAT/LONG,Facility Locked
_IBEAM Inspection,list date draft is submitted —IBEAM LAT/LONG,Coordinates checked
—IBEAM Inspection,pollutants/programs checked X IBEAM Complaint
—IBEAM Planning,Next Inspection Date
Signature: Damao e A Dgm Report Date: 08/16/2022
Directions:From Mooresville Regional Office to Harrisburg, travel Highway 3 South (Coddle Creek Highway);
turn right on Odell School Road; turn right onto Poplar Tent Road due to a no left turn and make a u-turn at the
stop light heading east on Poplar Tent Road toward Interstate 85;Interstate 85 South; exit off Interstate 85
South onto Exit#48 Interstate 485 South to Matthews (Inner Loop); exit off Interstate 485 South at Exit#33—
Harrisburg(Highway 49); turn left off exit ramp onto University City Boulevard(Highway 49 North) and 1.8
miles turn right onto Galvan Way. The office is located on the left and facility on the right. The street address of
the office is 7315 Galvan Way. The street address of the facility is 7320 Galvan Way.

Galvan Industries, Inc.
August 11 and 12,2022
Page 2
Background:
Galvan Industries,Inc. is a hot dip galvanizing facility. This company uses molten zinc to galvanize the
structural and ornamental steel materials for various businesses and industries throughout the southeast. The
amount of steel materials processed by this company is dependent on customer orders. This company is
currently processing 1,800 to 3,000 tons of steel materials per month.
The steel materials are shot blasted; cleaned with sodium hydroxide and sulfuric acid;pre-fluxed with a mixture
of zinc chloride and ammonium chloride and zinc coated in a kettle to provide protection to the metal surface
against corrosion. This company also has a copper electroplating line; wire drawing machines and point and
chamfer machines at this facility. The operational hours of this company are currently two eight-hour shifts,
five days per week,fifty-two weeks per year for the galvanizing, cleaning,pre-fluxing and shot blasting
operations; and twenty-four hours per day, seven days per week,fifty-two weeks per year for the copper
electroplating process, wire drawing and point and chamfer operations and maintenance activities of this facility.
Galvan Industries,Inc. was issued Air Permit No. 03639R15 on April 20,2017 with an expiration date of March
31, 2025 for the construction and operation of air emission sources and control devices. Air Permit No.
03639R15 lists the control devices installed on the emission sources and other insignificant/exempt activities as
follows:
® bagfilter(ID No. BH-2; 5,340 square feet of filter area) installed on natural gas/propane fired hot dip
zinc galvanizing kettle(ID No. GK-1; 3.0 million But per hour maximum heat input; 14,000 pounds per
hour maximum process rate; 42 x 4.5 feet x 8.5 feet that used a dry galvanizing system;
® bagfilter(ID No. 13H-1; 3,500 square feet of filter area)installed on shot blasting machine(ID No.
SBM-I; 14,350 pounds per hour maximum process rate);
• natural gas/propane-fired boiler(ID No.IEX-9; 8.4 million Btu per hour maximum heat input);
s countercurrent liquid impingement packed tower type wet scrubber in series with an integral chevron
type mist eliminator(ID No. IEX-14; 8.7 square feet of filter area;40 gallons per minute minimum
liquid injection rate) installed on a copper electroplating process and
® storage tanks containing:
propane storage tank(ID No. IEX-12; 18,000 gallon capacity);
sodium hydroxide(NaOH)(ID Nos. IEX-1; 8,500 gallons capacity and IEX-15; 2 gallons capacity);
sulfuric acid(ID Nos. IEX-2, IEX-3,IEX-4,and IEX-11;three at 14,100 gallons capacities,each and
one at 5,000 gallons capacity);
zinc chloride/ammonium chloride pre-flux(ID No. IEX-5; 8,400 gallons capacity);
water rinse(ID Nos.IEX-6; 14,100 gallons capacity and IEX-7; 9700 gallons capacity);
water quench(ID No. IEX-8; 18,000 gallons capacity); and
process water(ID No. IEX-13; 16,000 gallons capacity).

Galvan Industries, Inc.
August 11 and 12, 2022
Page 3
On August 9,2022, Ms. Denise Hayes of this office received a complaint regarding dust/smoke settling off
property at night from the Galvan Industries,Inc. facility located at 7320 Galvan Way, Harrisburg in Cabarrus
County. Ms. Hayes emailed and assigned this complaint to me for investigation on August 9, 2022.
I reviewed the MRO DAQ files to determine if this facility had any prior compliance history in the last five
years. The last routine air quality inspection was conducted by the assigned inspector, Ms. Karyn Kurek, on
January 12, 2022. During this inspection,this facility appeared to be in compliance with applicable air quality
rules.
The last complaint was received by MRO DAQ on June 9, 2021.No on-site investigation by the assigned
inspector, Ms. Melinda Wolanin, was conducted due to coronavirus pandemic restrictions. Previous complaints
were received by MRO DAQ staff and investigations were conducted on July 11,July 9 and June 26, 2018.
Based on the observations made during the complaint investigations on these dates, this office issued a letter
dated July 31,2018 to this company for Air Permit No. 03639RI5, General Condition and Limitation No. B. 6.
MRO DAQ requested in this letter to review the operations and consider additional measures to minimize
particulate emissions from the galvanizing building to ensure that compliance is met at all times with General
Condition and Limitation No. B. 6. This company responded in a letter dated August 27, 2018 to minimize
fugitive dust from road surfaces, galvanizing building,pickle bay and cleaning baths. This company appeared
to be complying with minimizing particulate emissions at this facility as noted during the last routine air quality
inspection on January 12, 2022 by Ms. Karyn Kurek.
Complaint Investigation on August 11 and 12,2022:
At 10:30 am on August 11,2022,Mr. Ryan Mills and I met with Damon Grant, maintenance manager, located
at the plant office, 7315 Galvan Way, Harrisburg in Cabarrus County to discuss the dust complaint. Mr. Grant
stated that the galvanizing kettle was down for maintenance and the plant manager, Mr.Harshad Londhe,was
out of office for the day. I informed Mr. Grant that the air quality complaint investigation would be conducted
on another day,when the galvanizing kettle(ID No. GK-1) is operating and Mr. Londhe is present at this
facility.
At 10:00 am on August 12,2022,1 met with Mr. Harshad Londhe,plant manager,at the office to discuss the
complaint and the operational status of the emission sources and control systems and the conditions and
limitations of Air Permit No. 03639R15. Mr.Londhe escorted me across Galvan Way roadway to the plant site
located at 7320 Galvan Way. During the site investigation,the following air emission sources and control
devices were noted as follows:
® The hot dip zinc galvanizing kettle(ID No. GK-1)and the bagfilter (ID No. BH-2)were in operation
with no visible emissions observed or any odors detected. The primary fuel source for the kettle is
natural gas. The secondary fuel source is propane. The propane is stored in one storage tank(ID No.
IEX-12; 18,000 gallons capacity).
This facility uses forklifts to move steel materials in and out of the galvanizing building that is open on
either end. The steel materials are conveyed by monorail to the galvanizing kettle. There are walls
surrounding the kettle and doors on either end that close unless the steel materials are oversized.
The blocks of molten zinc are melted and heated to 840 degrees Fahrenheit by 32 burners with 16
burners on one side and 16 burners on the other side of the natural gas-fired kettle. These burners heat
bricks,which radiate heat to the natural gas-fired kettle. The kettle exhausts through a vertical stack
with a rain cap to the outdoor atmosphere.

Galvan Industries,Inc.
August 11 and 12, 2022
Page 4
This facility had previously used roof top fans in the ceiling of the galvanizing building to exhaust any
particulate emissions from the natural gas-fired kettle to the outdoors. The roof top fans were not on
during the investigation. No visible or fugitive emissions were observed in the roof area of this facility.
The steel materials are lowered into the natural gas-fired kettle and then galvanize in it. The galvanizing
process takes five to ten minutes in the natural gas-fired kettle. The steel materials are dipped every 20
minutes or 3 to 4 dips per hour. After the galvanizing process,the steel materials are lifted out of the
kettle and the doors are opened. The steel materials are transferred from the kettle to an open water
quench tank(ID No. IEX-8), which is located in front of the kettle. The open water quench tank(ID
No. IEX-8)does not have any controls installed on it. After quenching, the steel materials are removed
from the galvanizing building and allowed to air dry outside of this facility.
The right side wall above the kettle has six holes that are ducted to the pulse jet type bagfilter(ID No.
BH-2)that collects any fugitive particulate matter emissions from the galvanizing process. The pulse jet
type bagfilter(ID No. BH-2)is located outside of this facility. The bagfilter exhausts through a vertical
stack with a horizontal rain cap to the outside atmosphere. This company has a pressure differential
gauge measured in inches of water installed on the bagfilter. The pressure differential gauge on the
bagfilter read t/2 inch and then after pulsing to 1 inch of water.
® The bagfilter(ID No.BH-1)and the shot blasting machine(ID No. SBM-1)were not in operation at the
time of the investigation. The metal materials are conveyorized into the chamber of the shot blasting
machine(ID No. SBM-1). The steel shot beads are used as the blast medium in the chamber of the shot
blasting machine to remove scale from the surfaces of metal materials prior to galvanizing or not
galvanizing as requested by customers. The steel shot beads are recovered and reused in this process.
The shot blasting machine is located inside of the blast building. The shot blasting machine is vented to
a shaker type bagfilter. The shaker type bagfilter is located outside of the blast building. The stack of
the bagfilter is vertical and uncapped. Mr.Londhe stated that there is no abrasive blasting being done
outside of this facility.
® The storage tanks for the sodium hydroxide(NaOH)(ID No. IEX-1); sulfuric acid(ID Nos.IEX-2,
IEX-3 and IEX-4);water rinse tanks(IEX-6 and IEX-7); process water tank(ID No.IEX-13)and zinc
chloride/ammonium chloride pre-flux(ID No. IEX-5)were in use at the time of the investigation with
no visible emissions observed or any odors detected.
The steel materials are placed on chains or racks and then transported by forklift to the sodium
hydroxide(NaOH)tank(ID No.IEX-1)and the three sulfuric acid tanks (ID Nos.IEX-2,IEX-3 and
IEX-4). The scale is removed from the steel materials in the cleaning process using sodium hydroxide
and sulfuric acid prior to the galvanizing process. The NaOH tank contains a solution concentration of
50% sodium hydroxide and water. Each of the three sulfuric acid tanks contain a solution concentration
of 8%to 10%sulfuric acid and water. Both the NaOH tank and the three sulfuric acid tanks are heated
to varying temperatures by the permit exempt natural gas-fired boiler(ID No.IEX-9). The pickling
process using bubbles from the sulfuric acid in the three tanks(ID Nos.IEX-2,IEX-3 and IEX-4)to
remove the scale from the steel materials varies from 5 minutes to an hour. After the cleaning process
in the NaOH and sulfuric acid tanks,then the steel materials are placed in tanks containing water(ID
No. IEX-6 or IEX-7)for rinsing purposes. Then the steel materials are removed from the tanks and
allowed to air dry.
The process tank(ID No. IEX-13)is used as a holding tank to store any liquid solutions of sulfuric acid
or NaOH until the fallen steel materials can be recovered from the bottoms of the tanks.

Galvan Industries, Inc.
August 11 and 12,2022
Page 5
After the cleaning process,the steel materials are dipped into the tank(ID No. IEX-5) containing the
zinc chloride/ammonium chloride solution prior to the galvanizing process in the kettle. The tank is
heated to temperatures ranging from 130 to 140 degrees Fahrenheit by the permit exempt natural gas-
fired boiler(ID No. IEX-9). After the pre-flux process,the steel materials are removed from the tank
and allowed to air dry.
® The permit exempt steam boiler(ID No. IEX-9)was in operation with no visible emissions observed.
The boiler is used to heat the one sodium hydroxide(NaOH)tank(ID No. IEX-1); three sulfuric acid
tanks(ID Nos. IEX-2, IEX-3 and IEX-4)and one zinc chloride/ammonium chloride pre-flux tank(ID
No. IEX-5). The primary fuel source for boiler is natural gas. The secondary fuel source for the boiler
is propane. The boiler exhausts through a vertical stack with a rain cap to the outdoor atmosphere.
There are two boiler blowdown pipes from the steam. No steam was observed from the two boiler
blowdown pipes at the time of the investigation.
® The countercurrent liquid impingement packed tower type wet scrubber in series with an integral
chevron type mist eliminator(ID No. IEX-14; 8.7 square feet of filter area; 40 gallons per minute
minimum liquid injection rate) installed on a copper electroplating process and the wire drawing and
point and chamfer processes were in operation with no visible emissions observed.
The coiled steel wires are die pulled, straighten and cut into rods by the two wire drawing machines.
The one wire drawing machine is located in building near the office. The other wire drawing machine is
located in the plating/ground rod building. The rods are cleaned in the tank (ID No IEX-15)containing
sodium hydroxide(NaOH)to remove any grease and then placed in the sulfuric acid tank(ID No. IEX-
11). After the cleaning process,the rods are nickel plated, electrically charged in the cooper sulfate
plating solution in four tanks; rinsed,.polished; pointed and engraved by the three point and chamfer
machines.
The packed tower type wet scrubber is used to capture any emissions from the copper electroplating
process. The packed tower type wet scrubber is located behind the plating/ground rod building. The
stack of the wet scrubber is vertical with baffles inside to keep out the rain.
Mr. Londhe stated that that none of the above referenced air emission sources and control devices have been
modified or its associated exhaust stacks changed since the previous full compliance evaluation conducted on
January 12,2022.
The visible emissions from the emissions sources at this facility are limited to 20% opacity when averaged over
a six-minute period as required by 15A NCAC 2D .0521 "Control of Visible Emissions"and as specified in
permit condition No.A. 6. of the current permit. The fugitive dust rule, 15A NCAC 2D .0540 "Particulates
from Fugitive Dust Emission Sources," and as specified in permit condition No. A. 8. states that the permittee
shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundaries. I observed no visible or fugitive dust emissions from the emission
sources and control devices or from the plant roads. The plant roads were wet and muddy at the time of the
investigation. Mr. Loudhe stated that this facility has a water truck to wet the unpaved dirt and gravel roads on
the plant premises.
This company is not allowed to operate this facility without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the emission sources from
the facility from causing or contributing to objectionable odors beyond the facility's boundary as required by
15A NCAC 2D .1806 "Control and Prohibition of Odorous Emissions" and as specified in permit condition No.
A. 11. The last MRO DAQ complaint regarding odorous emissions was received and investigated on December
1, 2006. No odorous emissions were detected by me at the plant site or its property boundaries.

Galvan Industries,Inc.
August 11 and 12, 2022
Page 6
The permit condition No. A. 3. "Particulate Control Requirement" was added for compliance with the ambient
air quality standards for total suspended particulate matter shall not exceed 75 micrograms per cubic meter
annual geometric mean and the 150 micrograms per cubic meter maximum 24-hour concentration shall not be
exceeded more than once per year. The maintenance requirement of this permit condition is to resurface its
back lot by scraping and gravelling as necessary every six months. The recordkeeping requirements are to
record the resurfacing activities in a logbook. The records provided by Mr.Londhe indicated that the yard
resurfacing activities were conducted on July 2,2022;February 28,2022 and previously on October 5 and 6,
2021 (last date noted by Ms.Karyn Kurek during an inspection on January 12,2022). This facility appeared to
be complying with the maintenance and recordkeeping requirements of the permit condition No.A. 3.
This facility is also required by 15A NCAC 2D .0611 "Monitoring Emissions From Other Sources"and as
specified in permit condition No. A. 10. "Fabric Filter Requirements"to perform at a minimum an annual(for
each 12 month period following the initial inspection)internal inspection of the galvanizing kettle bagfilter(ID
No. BH-2)and shot blasting bagfilter(ID No. BH-1)and also conduct periodic inspections and maintenance
(I&M)of the two bagfilters as recommended by the manufacturer.
This company is required to keep written or electronic records of all inspections and maintenance activities for
the two bagfilters along with corrects made and dates of actions in the log book. This facility conducts internal
maintenance on both of the bagfilters(ID Nos. BH-1 and BH-2). This company also contracts the vendor of the
galvanizing kettle bagfilter(ID No. BH-2)to inspect and conduct any maintenance activities on it.
The logbooks for the two bagfilters(ID Nos. BH-1 and BH-2)have to be kept on-site and made available to
DAQ personnel upon request. The records provided by this company indicated that the inspection and
maintenance activities of the galvanizing kettle bagfilter(ID No. BH-2)were conducted internally on July 2,
2022;April 26,2022;April 4,2022; June 11, 2021 (last date noted by Ms.Karyn Kurek during an inspection on
January 12,2022)and previously on March 7,2021. The records also indicated that the inspection and
maintenance activities of the shot blasting bagfilter(ID No. BH-1)were conducted internally on January 10,
2022 instead of January 11,2022 as noted by Ms.Karyn Kurek during an inspection on January 12,2022 and
previously on January 4,2021. The records of the inspections and maintenance activities of the two bagfilters
are being kept as required by the permit condition No.A. 10.
This facility has no emergency generators or peak shaving generators, fire pump engines or gasoline storage
tanks. There are two aboveground diesel storage tanks that are exempt from air quality permitting per 15A
NCAC .02Q .102(g)(4). This company also has a recovery system to recover the spent liquid sulfuric acid into
crystal products and sells it as micro nutrients.
The air emission sources and control devices at this facility are not subject to any 40 CFR Part 60,NSPS or 40
CFR Part 63,NESHAP regulations. This facility is also not subject to requirements of the Chemical Accident
Release Prevention Program, Section 112(r)of the Clean Air Act.
Conclusion:
During the site investigation, I observed no visible emissions from the above referenced emission sources or
control devices and detected no odors from the galvanizing,cleaning, pre-flux and electroplating operations.
This facility appeared to be in compliance with the applicable air quality rules and regulations and Air Permit
No. 03639RI5 at the time of the investigation. No further action is warranted by DAQ at this time.
DLC:
c: MRO file
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