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HomeMy WebLinkAboutAQ_F_1400214_20210519_CMPL_InspRpt (4) NORTH CAROLINA DIVISION OF Asheville Regional Office AIR QUALITY Construction Attachments, Inc. NC Facility ID 1400214 Inspection Report County/FIPS: Caldwell/027 Date: 05/20/2021 Facility Data Permit Data Construction Attachments, Inc. Permit 10099/RO1 1160 Cal Court Issued 1/8/2016 Lenoir,NC 28645 Expires 12/31/2023 Lat: 35d 53.0738m Long: 81d 33.5490m Class/Status Small SIC: 3531 /Construction Machinery Permit Status Active NAICS: 33312/Construction Machinery Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Scott Hatton Scott Hatton Scott Hatton MACT Part 63: Subpart 6X Plant Manager Plant Manager Plant Manager (828)758-2674 (828)758-2674 (828)758-2674 Compliance Data Comments: Inspection Date 05/19/2021 Xet Inspector's Name Bob Graves Inspector's Signature: Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: -5- 12-1, Inspection Result Compliance Total Actual emissions in TONSIYEAR: TSP S02 NOX VOC CO PM10 * HAP 2014 0.1500 --- --- 1.67 --- 0.1500 1910.10 * Highest HAP Emitted(inpounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 06/12/2018 NOWNRE Part 63 -NESHAP/MACT Subpart XXXXXX Nine 06/21/2018 Metal Fabrication and Finishing Source Categories Area Sources Performed Stack Tests since last FCE:None Date Test Results Test Methods) Source(s)Tested Location: Construction Attachments, Inc. is located at 1160 Cal Court in Lenoir,NC. Caldwell County. 1) Directions: From ARO, take I-40 East to Jamestown Road exit. Turn left at light and go to Hwy 181 in Morganton. Turn right and look for signs for 18/64 to Lenoir. Follow 18/64 to Lenoir. Turn right at light at Southwestern Blvd By-Pass. Go approximately 1.5 miles to left at Kerr Concrete and go to Cal Court that goes to plant. Do not turn into plant, but go to end of road (Cal Court). Facility is at end of Road. 2) Facility Overview: Construction Attachments, Inc. is a machine and tool maker that produces attachments for machines such as bobcats and frontend loaders. This facility is permitted under Air Permit No. 10099RO1, effective from January 8, 2016, until December 31, 2023. Last inspection was conducted by Richard Morris on December 5, 2019. Safety: Safety shoes, glasses. Do not stare at any type welding operations. Current throughputs: 2020 Hours: 40 hrs/wk Employees: 35 shop, 10 office Inspection Narrative: On May 19, 2021, I traveled to Construction Attachments, Inc., and made an off-site, unannounced observation of the facility. The facility was observed in operation with no visible emissions (VE) or fugitive dust. No objectionable odor was detected. Due to the COVID- 19 Pandemic, DAQ staff are not physically going inside facilities to perform inspections. On May 21, 2021, at approximately 10:55AM, I called and spoke with Scott Hatton, Plant Manager. Based on my conversation with him, we discussed the following: • Verified the contacts based on FACFINDER printout. The new invoice contact is Amanda Corriher, CFO. All other contact information is current. • Bagfilter CD-1 has been replaced with like-for-like new Torrit Donaldson cartridge filter. This system was installed on 5/16/2016. CD-2 has been taken out of service and removed from site. Plasma punch associated with this control device has been replaced with a new plasma cutter that uses a water bath for emissions control. I asked for the most recent bag filter logbook entries. Last annual internal inspection for CD-1 with all of the filters change out was performed on 1/20/2021. The facility keeps a very good inspection and maintenance (I&M) logbook with recent entries of maintenance and list when the bag filters are change out. Monthly inspections and maintenance activities are performed. • I reviewed the 6X observations log. All were current with recent entries. MIG welding operation is done under roof. The roof has two collection ducts that vent to the roof. I did not observe any VE from any openings on the building. Mr. Hatton said there are a total of 15 welding stations of which 14 are usually all operating. Process Description: Metal sheets are received by facility and are cut to assemble parts for buckets, forklifts, and other machinery parts. After cutting the parts, they are cleaned and welded together. Protective coatings are applied to prevent rust and corrosion. 3) Emission Source and Regulatory Review: Permitted Sources are: Emission 3 Emission Source Control i Control System Source ID Description I System ID F Description E ES-1 ;one plasma cutter CD-1 one bagfilter NESHAP ? =(2,328 square feet of filter area) �ES-2 one r,lnc.mn r.,,,,nh CD-2 one bnrrfil*or (1,520 c.qunro boo+ e �€ t 1 NESHAP new plasma cutter jfilltef area) 3 CD-2 has been taken out of service and removed from site A new plasma cutter has replaced the plasma punch. F The new unit uses a water bath F for emissions control. 3 E ES-3 MIG welding operations _ N/A N/A NESHAP Insignificant Sources: Source of t Source Exemption Source of Title V Regulation TAPs? Pollutants? I-Spray booth - one spray booth ;(the spray booth does not apply coatings 2Q .0102 that contain MFHAP and is therefore not (c)(2)(13)(i) yes Yes :subject to 40 CFR 63, Subpart 6X) Stipulation Review: A.4 2D.0521 —Visible Emissions. In compliance. I did not observe any visible emission during my inspection. A.6 2D.0540—Fugitive dust Control. In compliance. Their facility is entirely paved. A.7 2D.0611 —Fabric Filter requirements. In compliance. The facility is keeping logbooks for the CD-1 bagfilter system and updating with maintenance and repair entries. CD-2 has been taken out of service and removed from site. A new plasma cutter has replaced the plasma punch. The new unit uses a water bath for emissions control. A.8 2D.111 —MACT for Nine Metal Fabrication and Finishing Source Categories. In compliance. Logbook appears to be current. A.9 2D.1806—Control of Odorous Emissions. In compliance. I did not detect any odors leaving the facility property. Reporting requirements: There are three reporting requirements in the current permit. Each one is associated with the metals finishing operations for MACT 6X. a) An Initial Notification- shall be submitted no later than July 25, 2011 for any existing source subject to this Subpart. The notice shall contain the following information: A. The name, address, phone number, and e-mail address of the owner and operator; B. The address (physical location) of the affected source; C. An identification of the relevant standards (in this case 40 CFR 63, Subpart XXXXXX); and D. A brief description of the type of operation. In compliance. Notice received on time. b) A Notification of Compliance Status (NOCS) - shall be submitted on or before November 22, 2011 for any existing source subject to this Subpart. The Notice shall contain the following information: A. The company's name and address; B. A statement by a responsible official with that official's name, title, phone number, e-mail address, and signature certifying the truth, accuracy, and completeness of the notification and a statement of whether the source has complied with all the relevant standards and other requirements of this Subpart; and C. The date of the notification of compliance status. Late: Due November 22, 2011. Received December 19, 2011. c) An Annual Compliance Certification (ACC) - shall be submitted by January 31 of each year for the previous year. The report shall contain the following information: A. Company name and address. B. A statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report. C. Date of report and beginning and ending dates of the reporting period. D. The date of every visual determination of fugitive emissions which resulted in detection of visible emissions, a description of the corrective actions taken subsequent to the test, and the date and results of the follow-up visual determination of fugitive emissions performed after the corrective actions. E. An exceedance report shall be submitted along with the annual compliance certification whenever the average of the six-minute average opacities recorded during a visual determination of emissions opacity exceeds 20 percent. The exceedance report shall include the date on which the exceedance occurred and the average of the six-minute average opacities recorded during the visual determination of emissions opacity. F. If a Site-Specific Welding Emissions Management Plan is required according to 63.11516(f)(7)(iii), records of daily visual determinations of emissions recorded, a copy of the plan and any revisions to the plan shall be submitted along with the annual compliance certification. Due by January 31, 2021. Received on January 25, 2021. Report demonstrates compliance. 4) Compliance History Review: NRE issued June 12, 2018 for late reporting. 5) Stack Test Review: No stack test has been required for this facility. 6) 112R Status: Based on the facility's inventory, it was decided that they are not subject to 112R reporting requirements 7) Comments and Compliance Statement: Based on review of records and visual observations, this facility appeared to be operating in compliance with the Air Quality standards and regulations at the time of this inspection. lqo6 q RECEIVED 11, jj.1) J A N 2 5 2021 Division of Air Quality January 18,2021 Asheville Regional Office f c _. To Whom It May Concern: This letter is being sent to you as an Annual Compliance Certification in order to stay compliant with the terms of our air permit#10099. The name of our company is Construction Attachments, Inc. and our physical address is 1160 Cal Ct., Lenoir,NC 28645 L Scott Hatton, certify that Construction Attachments, Inc. has complied with all relevant standards and requirements that are called out in our air permit for the reporting date of January 111 2020 to December 31, 2020. 1, Scott Hatton,, certify that this is a true and accurate statement and our emission sources have been monitored, tracked, and checked to the best of our ability. See attached sheets for visual determination of fugitive emission dates. 1. Scott Hatton, am the Plant Manager, and I am the responsible official acting on behalf of Construction Attachments, Inc. My email address is aggttOgatnif om and our business phone number is (828)758-2674. Sincerely, Cot Scott Hatton Plant Manager TEL:828-758-2674*FAX:828-754-1887 www.calmfg.com CD-1 PLASMA PERMIT # 10099R00 Emission Source ES-1 Plasma Cutter Cartridges Magnehelic Date Cleaned System Bags Removed Weight Removed Reading Comments 0 7;L Y. 7 jr 179 dia .� 1-/1 19 ;f 1p- /4 q ,�erv-lk'nef Wa Alo• pAlf Av r - ! V� e) A,16 Al J CD-1 PLASMA -_ PERMIT# 10099R00 - Emission Source ES-1 Plasma Curter Cartridges Magnehelic Date Cleaned System Bags Removed Weight Removed Reading Comments A)O �Te Z/�ooz�-1 a r e d ,. f DVL04 w Q y ATO a 9-,gq X�2 o6QAeg=:� Aflo A/I ' EV SHEET , Date Emissions Viewed Time r ` A)Z2 / • 1 AL M v , ) aa a 9 4 A& A2.4- . �� a AO n e /"rya /3,' It --23 e 20 i"r AkIr 92 30 1, aIY6