AQ_F_0500075_20210902_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY American Emergency Vehicles, Inc. -Remount
Facility
Inspection Report NC Facility ID 0500075
Date: 09/02/2021 County/FIPS: Ashe/009
Facility Data Permit Data
American Emergency Vehicles, Inc.-Remount Facility Permit 10496/RO1
101 Gates Lane Issued 3/19/2019
Jefferson,NC 28640 Expires 4/30/2024
Lat: 36d 25.5501m Long: 8 1 d 28.9002m Class/Status Small
SIC: 3711 /Motor Vehicles And Car 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
Gary Graybeal Greg Warmuth Jeff Dreyer MACT Part 63: Subpart ZZZZ
Compliance Manager Vice President of Finance Process Control Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 09/02/2021
Inspector's Name Ryan Dyson
Inspector's Signature: DMM Operating Status Operating
Compliance Status Compliance-inspection
Action Code PCE
Date of Signature: �q( '2.77 Inspection Result Violation
Total Actual emissions in TONSIYEAR:
TSP SO2 NOX VOC CO PM10 * HAP
No emissions inventory on record.The emissions inventory is due 01/31/2024.
* Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
.01/09/2019 NOV 2Q .0 10 1 Required Air Quality Permits 03/19/2019
Performed Stack Tests since last FCE: None
Date Test Results Test Method(s) Source(s)Tested
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Permitted Emission Sources
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Emission Emission Source Control Control System
Source ID � Description System ID Description
ES-1 Glue Spray Booth _ N/A N/A�
ES-2 Dry Filter Paint Spray Booth equipped with a 3.58 mmBtu/hr. I N/A N/A
Natural Gas-fired Burner,direct-fired _
ES-3 Dry Filter Prime Spray Booth equipped with a 3.11 mmBtu/hr. N/A N/A
Natural Gas-fired Burner,direct-fired
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ES-4 Dry Filter Paint Spray Booth equipped with a 3.58 mmBtu/hr. N/A N/A
Natural Gas-fired Burner,direct-fired_ _ III
ES-5 Dry Filter Paint Spray Booth equipped with a 3.11 mmBtu/hr. N/A N/A 4WWV Vv
Natural Gas-fired Burner,direct-fired
ES-6 Wood Working Operations CD-6 fabric filter(1,830 square feet
of filter area) _
ES-7 ISolvent Recovery Process with integral process condenser N/A j N/A
Insignificant/Exempt Activities
Source Exemption Source of Source of Title V
Regulation TAPS? Pollutants?
I-ES-1 -Body Prep Areas equipped with two(2)Natural Gas-fired Pressure 2Q.0102 Yes Yes
'Washers(0.82 mmBtu/hr.,total),direct-fired (h)(1)(B)
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I-ES-2-Welding Operations �2Q.0102(h)(5) Yes Yes
'I-ES-3 -natural gas-fired emergency generator(100 kW rated capacity) 72Q .0l02(h)(5) Yes Yes
[NESHAP-ZZZZ] _..._..._............. _._..__..__...�.__...__..�...�___...._._.�
Introduction/Discussion
On September 2,2021,Mr. Ryan Dyson,Environmental Specialist for the Winston-Salem Regional Office of the North Carolina
Division of Air Quality(WSRO-DAQ),contacted Mr. Gary Graybeal,Compliance Manager,and Mr. Mike Absher,Maintenance
Manager,for a Partial Compliance Evaluation(PCE)of American Emergency Vehicles, Inc.-Remount Facility.This facility was not
targeted for an inspection.However,while conducting an inspection of the Halcore Group, Inc.d/b/a American Emergency Vehicles,
Inc. (ID: 0500068)facility on September 2,2021,Mr. Dyson discovered that emission sources had been re-located from Halcore
Group,Inc.d/b/a American Emergency Vehicles,Inc. and placed in operation at the American Emergency Vehicles,Inc.-Remount
Facility.Therefore,Mr. Dyson conducted a PCE of the American Emergency Vehicles, Inc. -Remount Facility to determine what
emission sources had been re-located.
At the time of this PCE,Mr.Dyson discovered that the woodworking equipment,consisting of three table saws and a CNC router,
from facility 0500068 had already been re-located to this facility and installed in such a manner as to be routed to existing fabric filter
CD-6. One of these re-located table saws,and the re-located CNC router were observed in operation at the time of this inspection.
This facility is already permitted for a single glue spray booth(ES-1).However,an additional glue spray booth was observed in
operation at the time of this inspection.Mr. Graybeal stated that this was glue spray booth ES-10 from facility 0500068 that had been
re-located and placed in operation at this facility.The exhaust from this glue spray booth routes out to the atmosphere.Mr. Graybeal
explained that the facility intends to use glue spray"ES-10"instead of ES-I moving forward. However,ES-1 is still connected and is
operational at the Remount Facility,according to Mr. Graybeal.Mr. Graybeal provided the Safety Data Sheet(SDS)for the glue that
is currently being used in the re-located glue spray booth(ES-10)at the Remount Facility via email on September 15,2021.
According to the provided SDS,Wilsonart NF942/NF943 Nonflammable Spray Grade Contact Adhesive is currently used in spray
booth ES-10 at the Remount Facility.According to the SDS,this product does include,among other ingredients,benzene,which is a
VOC and registered HAP/TAP. Mr. Graybeal also indicated that the Remount Facility is planning on installing 3 new paint spray
booths and a prep station at the Remount Facility at some point next year.
Mr. Graybeal indicated that the company also has plans to re-locate the methyl ethyl ketone(MEK)recycling unit(ES-9)from the
Halcore Group,Inc.d/b/a American Emergency Vehicles,Inc.facility to the American Emergency Vehicles,Inc.-Remount Facility.
However,this has not yet occurred.The company will also be re-locating some exempt sources. For instance,the exempt 500-gallon
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aboveground gasoline storage tank(I-ES-14)and exempt 500-gallon Aboveground Diesel Storage Tank(I-ES-15)have been drained
and placed in storage at the Remount Facility.Mr. Graybeal indicated that the two exempt natural gas-fired hot water heaters(I-ES-I I
and I-ES-12)from facility 0500068 will also eventually be re-located to the Remount Facility.
The Halcore Group,Inc. d/b/a American Emergency Vehicles,Inc. facility also had some equipment that was not required to be listed
on the insignificant/exempt activities attachment.This included some woodworking equipment controlled by an internally exhausting
sock filter,and a glue station that has an integral filter,does not exhaust outdoors and uses 3M Fast Track Water Based Adhesive that
does not contain any VOCs,TAPs or HAPs, according to the Permit Applicability Review written by Mr.Leo Governale,
Environmental Engineer for the WSRO-DAQ,dated January 11,2017.Both the woodworking equipment with the internally
exhausting sock filter and the glue station described here have also been re-located to the Remount facility. Mr. Graybeal indicated
that all other permitted and exempt sources from the Halcore Group,Inc.d/b/a American Emergency Vehicles,Inc.will remain at that
site when the facility ceases operations around August of 2022.
5 Year Compliance History
The facility was issued a NOV on January 9,2019 for constructing and operating a dry filter paint spray booth,woodworking
operation with associated bagfilter,and solvent recovery distillation unit without an Air Quality Permit.The WSRO-DAQ received an
application package from this facility on January 4,2019,requesting a modification of Permit Number 10496R00.The facility's
current permit(Air Permit No. 10496R01), issued on March 19,2019,contains the equipment mentioned above,and resolved this
violation.There have been no other compliance issues associated with this facility in the last five years.
Conclusion
Based on visual observations and record review,American Emergency Vehicles,Inc.-Remount Facility appeared at the time of this
PCE to be in violation of 15A NCAC 02Q .0101,"Required Air Quality Permits,"for constructing and operating a source subject to
an applicable standard,requirement,or rule that emits any regulated pollutant without obtaining an air quality permit for that
equipment,and North Carolina General Statute 143-215.108,for altering or changing the construction or method of operation of any
equipment or process from which air contaminants are or may be emitted,without permit coverage for that equipment and/or activity.
American Emergency Vehicles, Inc. -Remount Facility will be issued a NOV/NRE for its second offence of violating 15A NCAC
02Q .0101 and North Carolina General Statute 143-215.108.This letter will request that a permit application be submitted to the
WSRO-DAQ to address the changes in the facility's emission sources.
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