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HomeMy WebLinkAboutAQ_F_2000115_20220411_CMPL_InspRpt (4) 70001I6 - /� �� NORTH CAROLINA DIVISION OF Asheville Regional Office AIR QUALITY Moog, Inc. NC Facility ID 2000115 Inspection Report County/FIPS: Cherokee/039 Date: 04/12/2022 Facility Data Permit Data Moog, Inc. Permit 07680/R06 1995 Hwy 141 Issued 6/4/2014 Murphy,NC 28906 Expires 5/31/2022 Lat: 35d 5.6640m Long: 83d 56.7840m Class/Status Small SIC: 3621 /Motors And Generators Permit Status Active NAICS: 335312/Motor and Generator Manufacturing Current Permit Application(s) Renewal Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Danielle Loyd R Keaton Danielle Loyd MACT Part 63: Subpart 6H,Subpart 6W, Subpart Environmental Health & General Manager Environmental Health& 6X,Subpart N Safety Engineer (828)837-5115 Safety Engineer (828)837-5115 (828)837-5115 Compliance Data Comments: Inspection Date 04/11/2022 Inspector's Name Steven Ensley Inspector's Signature: � /' Operating Status Operating Compliance Status Compliance- inspection Action Code FCE Date of Signature: `-� �Z 2� Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 X HAP 2020 --- --- --- 0.0700 --- --- 59.56 2012 0.0300 --- --- 0.8800 --- 0.0200 34.81 Highest HAP Emitted inpounds) Five Year Violation History:None Date Letter Type Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested Directions: The plant is located on State Highway 141 in Peachtree. From US 74, at Marble, turn left on 141 and travel approximately seven miles to Peachtree. The plant is on the right on 141. Moog,Inc. Inspection Report Page 2 of 5 Description: This facility manufactures avionics and other small motors and gauges. On April 11, 2022, I met with facility contact Danielle Loyd and Mr. Mike Murray to inspect the facility. Mr. Murray is the assistant to Environmental contact Danielle Loyd. Ms. Loyd stated that there had been no changes or modifications to the facility since the last inspection. Ms. Loyd explained that while the demand for bi-pap and the other breathing assist products was down since last year with the waning of Covid,they have had increased orders for other products like parts they manufacture for the Javelin anti-tank missile. Permitted Items ... ......... .............. ...... ...... ...,. ..........._..... Emission Emission Source Control Control System Source ID Description System ID Description ......... ...... -- ....................................... 001 and 016 two water curtain type paint spray booths used in a metal N/A N/A (GACT) ;parts coating operation 007 (GACT) one nickel plating line N/A N/A ....... ........ ....................................... _.. ... O11 one chromium anodizing operation(tank surface area of (MACT) 13.5 square feet) N/A N/A ... . ......................... ....................._................................... .............._....................................... ;............ ........................... 012 one sodium dichromate passivating operation N/A N/A (GACT) ....................... ........ ............ ...... .............. .............. ...... ... ............ ... ._ ............. ...... . 1. two water curtain-type paint spray booths (ID No. 001 and 016) used in a metal parts coating operation; VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D .0521 "Control of Visible Emissions," visible emissions from the nickel plating line (ID No. 007) and the spray booth(ID No. 016), manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged over a six-minute period... Observed but not in operation during inspection. 0% visible emissions. 2. one nickel plating line (ID No. 007); VISIBLE EMISSIONS CONTROL REQUIREMENT -As required by 15A NCAC 2D .0521 "Control of Visible Emissions," visible emissions from the nickel plating line (ID No. 007) and the spray booth(ID No. 016), manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged over a six-minute period. This line operates infrequently as job demand requires. Observed but not in operation during inspection. 0% visible emissions. Moog, Inc. Inspection Report Page 3 of 5 3. one chromium anodizing operation (ID No. 011); a. MALT Emissions Limitations - During tank operation the surface tension of the electroplating bath for the affected source shall not exceed: . ..........................................: Pollutant Emission Limit(s) Affected Source(s) (dynes/cm) chromium anodizing operation. 45 (ID No. 011) Logbook records indicate surface tension measurements were well below the 45 dynes/cm limit with most readings 34 or 35 dynes/cm. b. VISIBLE EMISSIONS CONTROL REQUIREMENT - As required by 15A NCAC 2D .0521 "Control of Visible Emissions," visible emissions from the spray booth (ID No. 001) and the chromium anodizing operation (ID No. 011), manufactured as of July 1, 1971, shall not be more than 40 percent opacity when averaged over a six-minute period... Observed but not in operation during inspection. 0% visible emissions. 4. One sodium dichromate passivating operation (ID No. 12): Passivation removes the surface contamination created when stainless steel is machined and fabricated. These contaminants can result in premature corrosion that could ultimately damage the component. In addition to surface cleaning, passivation forms a thin, transparent oxide coating that fights selective oxidation. Observed but not in operation during inspection. Fugitive Dust Control Requirement No fugitive dust emissions were observed beyond the property boundary. Work Practices Requirements 1. VOC-containing material was properly stored and no spills or waste rags were observed. No parts washing was observed. Although no longer a requirement, permitted work practice standards appeared to be met. 2. The work practice standards for the stalagmometer recommended by the manufacturer were being followed. Moog, Inc. Inspection Report Page 4 of 5 MACT, Subpart N - Decorative Chromium Electroplating and Chromium Anodizing Tanks 1. The operation and maintenance plan for the anodizing operation required to comply with MACT monitoring and work practices was observed. This plan is maintained electronically on site. 2. The surface tension of the electroplating bath was checked at least every 4 hours of operation to verify compliance with MACT Emissions Limitations requirement that the tension shall not exceed 40 dynes/cm. Records were observed to be in compliance. GACT, Subpart XXXXXX - Standards for Metal Fabrication and Finishing Operations a. Standard and Management Practices—the facility appeared to be following the standard and management practices. b. Recordkeeping Requirements- Observation of this record was accidentally omitted by the inspector, however previous inspections have been in compliance. c. Reporting- Report received on 1/24/22 indicating compliance CONTROL AND PROHIBITION OF ODOROUS EMISSIONS - As required by 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. No objectionable odors were observed beyond the facility's boundary. Exempted Activities Source Exemption Source of Source of Title V Regulation TAPs? Pollutants? I-008 - one zinc phosphate coating line 2Q .0102 No Yes (c)(2)(E)(i) I-014 - one bead blast operation (M3333 2Q .0102 BlastnPeen) (vented inside, controlled by No No (c)(1)(L)(ix) bagfilter) (GACT 6X) I-015 - one bead blast operation (M3264 2Q .0102 Silverado) (vented inside, controlled by No No (c)(1)(L)(ix) bagfilter) (GACT 6X) Moog, Inc. Inspection Report Page 5 of 5 I-016 - one rust preventer line 2Q .0102 No No (c)(1)(L)(xii) I-017 - one air compressor heat evaporator. 2Q .0102 No Yes (c)(2)(E)(i) 1. one zinc phosphate coating line (1-008) - Observed. 2. one bead blast operation (M3333 BlastnPeen) (vented inside, controlled by bagfilter) (GACT 6X) I-014. —Observed. Typically operates 1 day/month. 3. one bead blast operation (M3264 Silverado) (vented inside, controlled by bagfilter) (GACT 6X) I-015. - Observed 4. one rust preventer line 1-016- Removed from facility. 5. one air compressor heat evaporator I017. Observed. This facility operates a mostly automated line that produces bi-pap and other breathing assist devices. None of these lines appear on the permit, however I learned that there was a gluing component to the manufacturing process. I requested that Ms. Loyd submit information about the gluing process including usage, and capture efficiency for the control devices which are all vented inside. Submitted data indicate that emissions are very small however the permit engineer may want to add the process to the insignificant list. 5 Year Compliance History A review of the 5 year compliance history revealed no compliance issues. Compliance Statement: Moog, Inc. appeared to be in compliance by inspection with permit No. 07680R06. The permit engineer may want to add the aforementioned gluing process to the insignificant list.