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HomeMy WebLinkAboutAQ_F_2000132_20210824_CMPL_CAV-Rpt (4) NORTH CAROLINA DIVISION OF Asheville Regional Office AIR QUALITY Snap-on Power Tools NC Facility ID 2000132 Inspection Report County/FIPS: Cherokee/039 Date: 08/24/2021 Facility Data Permit Data Snap-on Power Tools Permit n/a 250 Snap-on Drive Issued n/a Murphy,NC 28906 Expires n/a Lat: 35d 6.7260m Long: 84d 0.2580m Class/Status Registered SIC: 3546/Power Driven Hand Tools Permit Status Inactive NAICS: 333991 /Power-Driven Handtool Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Joe Wilson Joe Wilson Joe Wilson Manager,Distribution Manager,Distribution Manager,Distribution and Safety and Safety and Safety (828)835-4407 (828)835-4407 (828) 835-4407 Compliance Data Comments: Inspection Date 08/24/2021 Inspector's Name Mamie Colburn Inspector's Signature: '�/' ,.�� Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: G�' � � Inspection Result Compliance Total Actual emissions in TONSIYEAR: TSP S02 NOX VOC CO PM10 *HAP No emissions inventory on record. * 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 I-40 W,take US -74W via exit 27 towards Clyde/Waynesville/Murphy/Atlanta/Maggie Valley. Merge onto US-74W. Continue onto US-74 W/ Great Smoky Mountains Expressway. Drive to State Rd. 1624. Pass Harrah's Casino Cherokee Valley River. Turn left onto Lovin Rd. Slight right onto State Rd 1624. Snap on is at dead end. There is a gate and call button to enter the parking lot. Safety Equipment: eye protection,hearing protection Facility Contacts: Mr.Wilson is the EHS manager and facility contact. He confirmed that all contacts were up to date. Facility Description: Snap-On operates a manufacturing facility for pneumatic power tools. Operations include machining and tool assembly—including metal heat treating, endothermic gas surface treatment, dip treatment/coating lines,washing, powder coating, and drying. Snap-on operates 3 shifts, 5-6 days per week. The facility is split into four zones: office, machining; assembly; shipping. All air emission sources are in the machining portion of the facility. This facility(formerly known as Sioux Tools)received a"Permit Applicability Determination"in 2002 that the facility's operations were exempt from air permitting. The 7/31/2002 letter states in part: "should you decide to modify the process such that the result is an increase in emissions of air pollutants....an air permit may be required." The planned installation of a new paint spray booth at Snap-on Power Tools,Inc. led the company to request registration. Based on emissions of each criteria air pollutant of less than 5 tons/year, negligible TAP emissions, and aggregate emissions of less than 10 tons/year,this facility qualifies for permit exemption per 2Q .0102(d). However, in a 5/14/2020 telephone conversation, facility consultant Mike Fox communicated that the facility wanted to proceed with registration. Compliance Inspection Narration: I, Mamie Colburn, arrived on site to meet with Mr. Wilson at 10 am on Tuesday August 24, 2021. Prior to arrival, I called Mr. Wilson to confirm their COVID protocols and make sure there were no active outbreaks or restrictions. Masks and social distancing were in place and I followed those protocols upon arrival. Upon arrival, I met with Mr. Wilson in their conference room to review records and discuss the inspection process. This is their first DAQ inspection for their optional registration. Registration Criteria Review: Mr. Wilson and I discussed the current Facility Wide Emissions estimate of TSP/PM10 completed during the registration process in 2020. Mr. Wilson stated there have been no changes to the process or significant increases in production since that review. The following pollutant estimation are for the use of propane-fired equipment listed in the Air Emission Source Table. Snap-on Tools is currently calculated as an exempt facility but has chosen to be a registered facility. Using revised/corrected estimates of TSP/PM10 Emissions, estimated facility-wide potential emissions of criteria pollutants are: Pollutant TSP (PM10) NOx CO S02 VOC Estimated 0.1 2.4 1.4 0 0.2 emissions (Tons/year) Note that the potential emissions in the table above are from maximum propane combustion from all combustion sources(8760 hours/year at maximum burner ratings). As stated above,this facility could be exempt from permitting per 2Q .0102(d)which exempts: d)Any facility whose actual emissions ofparticulate matter(PM10), sulfur dioxide, nitrogen oxides, volatile organic compounds, carbon monoxide, hazardous air pollutants, and toxic air pollutants are each less than five tons per year and whose actual total aggregate emissions are less than 10 tons per year shall not be required to obtain a permit pursuant to 15A NCAC 02Q.0300. This Paragraph shall not apply to synthetic minor facilities that are regulated pursuant to 15A NCAC 02Q.0315. Emission Source Inspection: The following air emissions sources were viewed during an inspection of the facility. The majority of these sources are in the machining portion of the facility: Air Emission Source Heat input Seen?In Operation? Heat treat Furnace No. 1 0.58 mmBtu/hour In operation. No VE. (propane fired) maximum heat input rate Heat treat Furnace No.2 0.58 mmBtu/hour In operation.No VE. (propane fired) maximum heat input rate Temper Room No. 1 0.80 mmBtu/hour AKA—draw furnace. In operation. No (propane-fired) maximum heat input rate VE. Temper Room No.2 0.80 mmBtu/hour AKA—draw furnace. In operation.NO (propane-fired) maximum heat input rate VE. Wash/heat treat room 0.80 mmBtu/hour In operation. (propane-fired) maximum heat input rate Endothermic Generator 0.12 mmBtu/hour In operation. (propane-fired) maximum heat input rate Dip line consisting of four 0.12 mmBtu/hour Seen.Recently used. dip tanks and associated maximum heat input rate propane-fired burner Two dry filter type paint N/A In operation w/disposable filters. spray booths Pressure drop of A in each. No VE. Two heat treat furnaces, which are propane fired,were seen in operation in the machining room. Propane flares are visible on each of these furnaces. These furnaces are used to harden and cure machined metal parts for pneumatic drills. Temper room 1 & 2 are near the furnaces and were in operation. The wash/heat treat room was also seen in operation. Temperatures around the equipment is very high with open flames in some cases. I viewed this equipment from a 20-foot distance. The dip-line and propane fired burner had been used earlier in the day. Finished metal product was viewed at the end of this line. Filter-type spray booth was viewed in operation under negative pressure. Pressure drop was visible as -1 inch and Mr. Wilson stated the booths had disposable filters. Dates of filter change out were not readily available. In addition to the above-listed sources,the following operations are listed in the request for registration as operations which emit negligible air pollution(emissions not quantified). Operation Comment Seen? In operation? Powder paint cure Electrically heated In operation. oven/Heat Treat Room curing oven Gage Coating/Gage AKA—Wax dip Seen.Not in operation. Recently used Crib ALMCO Wash System In operation. Drying Oven/Plant Electrically heated Seen in operation at 1200 F drying oven The powder paint cure oven was on but functioning at a lower temperature than normal operations due to needing repair. The gage coating/gage crib is a small wax dip tank the size of a large sink. Wax is dipped onto metal ends to protect them in shipping. Dipped metal was observed.The Drying oven/Plant was seen in operation,running at 12000 F. Prior to going into the building I saw what appeared to be steam from a stack emitting from the south Side of the building. I spoke to Mr. Wilson about this and he said it was process steam. After the interior inspection, I walked to the outside of the building to view any potential emissions including this side stack. It did appear to be condensing steam.This steam is highly visible when viewing the building from afar. 112R: This facility is not subject to 112(r). Recordkeeping Requirements: This facility has no record keeping requirements. Reporting Requirements: This facility has no reporting requirements. Compliance History: This is the first compliance inspection.No previous violations. Compliance Assistance: Mr. Wilson and Snap-On do not require assistance at this time. Recommendations: None at this time. Compliance Statement: This facility is operating in a way that compliance is indicated.