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HomeMy WebLinkAboutAQ_F_0000074_20201215_CMPL_InspRpt NORTH CAROLINA DIVISION OF Asheville Regional Office AIR QUALITY Altec Industries,Inc. -Burnsville Facility NC Facility ID 0000074 Inspection Report County/FIPS: Yancey/199 Date: 12/15/2020 Facility Data Permit Data Altec Industries, Inc. -Burnsville Facility Permit 09587/R03 150 Altec Drive Issued 12/16/2015 Burnsville,NC 28714 Expires 11/30/2023 Lat: 35d 54.8198m Long: 82d 21.5802m Class/Status Synthetic Minor SIC: 3713/Truck And Bus Bodies Permit Status Active NAICS: 336211 /Motor Vehicle Body Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Jeff Mooney Jeff Mooney Bruce Stainbrook General Manager General Manager Corporate Environmental (828)678-5560 (828)678-5560 Manager (770)639-5141 Compliance Data Comments: Inspection Date 12/15/2020 Inspector's Name Amro Ali Inspector's Signature: Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: j 2 / 2 On-Site Inspection Result Compliance Total Actual emissions in TONSIYEAR: TSP S02 NOX VOC CO PM10 *HAP 2014 0.4700 0.0100 1.83 48.32 1.54 0.4700 1879.58 2009 1.96 --- 1.50 12.35 1.30 1.96 207.00 *Highest HAP Emitted(in pounds) 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: From Asheville,proceed east on I-26 to Hwy 19E. Proceed past Prices Creek and take the next left on to Old 19E. The facility is about 0.1 of a mile from that intersection on the right. Process Description Steel components are stamped and cut to size for utility truck cabinets. Steel panels are shaped if necessary and staged for fabricated. Once the units are welded together,they may be conveyed to one or more of the following; the dip-coating process line,the top-coat spray booth,the undercoating spray booth,the caulk booth and/or the touchup and rework spray booth. Some of the truck body are attached to stock truck bodies at the Burnsville facility,but most are staged for loading on flatbed truck trailers and are sent to the Altec facility in Creedmoor, North Carolina to be joined to truck bodies. Altec Industries, Inc. Burnsville Plant Page 2 of 5 Inspection Observations On December 15,2020,I conducted an announced air quality inspection of operations at Altec Industries,Inc. in Burnsville,North Carolina. Due to COVID-19, a virtual inspection was conducted through a Microsoft Teams Meeting Software. The facility's personnel toured the facility and I was able to see all of the facility's emission sources and emission stacks through a live video broadcast.The following were the attendants: Robin Sirkin—EH&S Manager David Tilly—Plant Manager Bruce W. Stainbrook—Corporate Environmental Regulatory Manager Keith Gwin—Corporate Environmental Manager During the previous compliance inspection,I discovered an onsite a diesel fired emergency generator that is used for backup lights for the facility and a backup for paint agitators. The emergency generator is 200 kW Olympian. It is equipped with an hour meter and had 96 hours of total run time. The facility runs the generator for approximately 30 minutes a month for maintenance purposes. According to the facility,the generator was installed on site in 2006. This generator is subject to 40 CFR 63, Subpart ZZZZ. It is, however,exempt from permitting because according to the memo dated January 24,2007,because the potential hours of operation is 500 hours for emergency generators. Therefore,this emergency generator is exempt from permitting because of potential emissions less than 5 tons per years. The facility,however,has to perform all the requirements set in Subpart ZZZZ. The facility is performing the maintenance requirements on the engine twice per year. The last maintenance on the engine was performed in August 10,2020,and the requirements set in Subpart ZZZZ were met which includes filter and oil change. The hour meter indicated 112 hours based on an email sent by the facility on December 9,2020. This generator should be discussed in the next permit review. During 2017 Altec also began using zirconium in the dip coating operation instead of the phosphate. This is not expected to impact air emission rates. The table below document observations of specific equipment: The facility was issued a 2Q.0318 permit exemption for touch-up paint booth PS-PB05. This paint booth should be added the next time the facility's permit is reviewed by DAQ. According to Mr. Stainbrook,this touch-up booth is not currently running,and is planned to start-up in January,2021. Each spray booth has a magnehelic gauge that alerts change of filters when the pressure reaches the 1"H20. The facility showed me via video,a view of the facility's stacks,and it appears that no visible emissions were emitted from any of the facility's stacks. Description ID No. Observations dip coating process line, ES-DCO1 Observed in operation with no visible emissions; see details consisting of approx. 12 dip on dip coating operation below. tanks and associated holding and mixing vessels"E-coat" natural gas-fired dip coating ES-DO01 It is no longer operating. The new process does not require curing oven(4.5 MMBtu/hr) heating due to change of chemicals.It has not been running for over a year. The facility wants to keep it in the permit. four filter-type paint spray ES-PBO1 Observed in operation with no visible emissions(Top Coat booths 1;used to touch-up assembled truck parts after E-Coat) ES-PB02 Observed in operation with no visible emissions(used to apply undercoating) ES-PB03 Observed in operation with no visible emissions(Top Coat 2;used to apply custom colors,clear coat and hardeners) Observed in operation(used as a final touch up booth) ES-PB04 Not yet operating,plan to operate in January 2021. ES-PB05 Altec Industries,Inc. Burnsville Plant .Page 3 of 5 Description ID No. Observations natural gas-fired paint booth ES-PO01 Equipment observed in operation with no visible emissions curing oven(4.5 MMBtu/hr) at the time of the inspection. caulk booth ES-CB 1 All seams are caulked after the E-Coat process. We observed that this process was in operation at the time of the inspection. Each stage of the dip coating operation(ES-DCO1)is labeled with the description in the following table. Note that Stage 6 was converted from zinc phosphate to zirconium surface treatment at the end of 2016. Stage Description 1 alkaline cleaner—Chemkleen 163—heated to 130-150°F. 22,345 gallon tank. 2 water rinse 3 water rinse(tank could be changed to acid cleaner in the future) 4 water rinse 5 rinse conditioner—RC GL—titanium based surface conditioner 6 zirconium surface treatment covers iron surface with a layer of zirconium oxide 7 water rinse 8 non-chrome sealer—Chemseal 100-organic passivating rinse 9 RO Rinse—reverse osmosis water 10 E-Coat—Powercron 600CX—heavy metal free,cationic epoxy paint solids 14-16%; 85-100°F(primer coat) 11 post rinse—"Permeate"—removes excess paint solids which are then transferred back to the E-Coat tank 12 post rinse—"Permeate"—removes excess paint solids which are then transferred back to the E-Coat tank After the final rinse,parts are lifted into the dip coating curing oven(ID No.ES-DOO 1)above the dip tanks. It takes approximately 2.5 -3 hours for each part to go through the dip coating operation and the paint booth curing oven. Rule Review 2D .0515-Particulate Emissions from Miscellaneous Industrial Processes-Emissions of particulate from any stack, vent,or outlet of any industrial process for which no other emission control standards are applicable shall not exceed the amounts calculated by the following equation: E=4.10xP0.61 where, E=allowable emission limit in pounds per hour P=process weight rate in tons per hour According to the initial permit application,the maximum process weight rate through the paint spray booth will vary depending on what parts are being coated. However,to be conservative,a process weight rate of 500 pounds per hour is assumed. Using the above equation,this relatively low process rate leads to an allowable emission rate of 1.62 lbs/hr. Based on information contained in the initial permit application,the calculated maximum hourly PM emission rate from the spray booths is 1.07 lbs/hr. The latest annual report states that the 12-month rolling total for the period ending December 2017 was 0.69 tons of particulate emissions. Assuming the facility operates 4800 hours per year(based on the 2014 Emissions Inventory),the result is about 0.2875 lb/hr. Compliance with 2D .0516 is indicated. 2D .0516-Sulfur Dioxide Emissions from Combustion Sources-This regulation limits S02 emissions from combustion sources to 2.3 pounds per million Btu. Sulfur dioxide emissions from natural gas combustion are 0.6 lb sulfur dioxide per million standard cubic foot(ref.AP-42 Table 1.4-2). The sulfur dioxide emission rate calculates as: (0.6 lb S02/ 1,000,000 scf) * (I scf/1020 Btu) * 1,000,000 Btu/1 mmBtu=0.000588 lb/mmBtu Altec Industries, Inc. Burnsville Plant Page 4 of 5 Compliance with 2D.0516 is indicated while combusting natural gas. We verified that all combustions sources were firing natural gas at the time of this inspection. 2D.0521 -Control of Visible Emissions-In order to comply with 2D .0521,the visible emissions from the facility shall not be more than 40 percent opacity when averaged over a six-minute period except that six-minute periods averaging not more than 90 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour period for sources manufactured as of July 1, 1971. For sources at the facility manufactured after July 1, 1971,visible emissions shall not be more than 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. At the time of the inspection,no visible emissions were observed from any of the operating emission sources. Compliance with 2D .0521 is indicated. 2D .0535 -Excess Emissions Reporting and Malfunctions-This regulation requires timely reporting and appropriate actions during periods of excess emissions and malfunctions. No such reporting has been received and I found no evidence that the facility has released excessive emissions due to abnormal conditions such as malfunction. 2D.0540 -Particulates from Fugitive Dust Emission Sources-This regulation was amended effective August 1, 2007. The regulation formerly addressed only certain types of processes. The amended regulation addresses all facilities with activities such as:unloading and loading areas,process areas, stockpiles,stockpile working,plant parking lots,and plant roads(including access roads and haul roads). The regulation requires a fugitive process dust plan and abatement measures if substantive complaints are verified. I was not able to see fugitive emissions at this facility during this virtual inspection, and there have been no complaints of such. Compliance with Rule 2D .0540 is indicated. 2D.1806 -Control and Prohibition of Odorous Emissions-This regulation requires the owner or operator of a facility to not operate without implementing 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. There have been no odor complaints with regards to this facility and odors could not be verified during this virtual inspection. Continued compliance with Rule 2D .1806 is indicated. 2Q .0315 -Synthetic Minor Facilities-This regulation allows facilities with potential emissions above major source thresholds to take voluntary,federally enforceable emission limitations to reduce their potential-to-emit and preclude Title V applicability. Although this facility would typically be classified as prohibitory small,Altec specifically requested synthetic minor classification instead. The facility tracks actual usage of each material containing VOC and HAP,and calculates monthly VOC and HAP emissions by mass balance. The latest annual report received from the Permittee covers 2019 and met the synthetic minor limits. Compliance with the synthetic minor emission limits and reporting requirements is indicated. 2Q.0711 -Emission Rates Requiring a Permit-The annual report of emissions for 2018 states that TAP emission rates are well under their respective Toxic Pollutant Emission Rates(TPERs)as shown below. TAP emission rates are expected to remain below applicable limits,and continued compliance with 2Q .0711 is expected. 2D.I I I I -Maximum Achievable Control Technology-Maximum Achievable Control Technology(MACT) as promulgated in 40 CFR 63, Subpart XXXXXX, National Emission Standards for Hazardous Air Pollutants Area Source Standards(NESHAPs)for Nine Metal Fabrication and Finishing Source Categories",for Machining (§63.11516(b))and Welding(§63.11516(f))processes-Initially,it was interpreted that Altec Industries was subject to regulation under 40 CFR 63, Subpart XXXXXX which applies to Metal Fabrication and Finishing Sources. Specifically,the rule applies to facilities that are primarily engaged in metal fabrication and finishing. Operating standards are required for machining operations that use materials containing metal fabrication and finishing Hazardous Air Pollutants(MFHAP). The rule is triggered if the MFHAP contains cadmium,chromium,lead,or nickel in amounts greater than or equal to 0.1 percent by weight,or contains manganese in an amount greater than or equal to 1.0 percent by weight. The triggering quantity for welding operations is 2,000 pounds per year of welding wire. The Permittee indicated that well over 2,000 pounds per year of welding wire was used and that the actual manganese content of the electrode wire was typically between 0.9 and 1.4 percent. Altec Industries,Inc. Burnsville Plant Page 5 of 5 However,it was later determined that neither the facility's Standard Industrial Classification(SIC)code,nor the North American Industrial Classification System(NAICS)code are not identified in the list of SIC/NAICS code combination included in Table 1 of the Federal Register(FR)publication of the final rule. Therefore,the facility is not subject to the rule. Starting with Air Permit No.09587R02,welding operations are listed as insignificant source with ID No. IES-WELD. Compliance History There have been no air quality compliance issues documented at this facility during the past five years. Conclusion and Comments At the time of the inspection,Altec Industries' Burnsville facility appeared to be operating in compliance with Air Quality Permit 09587R03. The touch-up paint booth(ID No.ES-PB05)should be added to the facility's permit,the next time the permit is reviewed.