AQ_F_0900049_20200915_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Taylor Mfg
NC Facility ID 0900049
Inspection Report County/FIPS: Bladen/017
Date: 09/23/2020
Facility Data Permit Data
Taylor Mfg Permit 06963 /R05
1585 US 701 South Issued 3/14/2016
Elizabethtown,NC 28337 Expires 2/29/2024
Classification Small
Lat: 34d 36.7370m Long: 78d 36.8200m
Permit Status Active
SIC: 3559/ Special Industry Machinery Nee Current Permit Application(s)None
NAILS: 333111 /Farm Machinery and Equipment Manufacturing
Program Applicability
Contact Data
SIP
Facility Contact Authorized Contact Technical Contact
Charles King Denise Bridgers Denise Bridgers
Plant Supervisor Secretary Treasurer Secretary Treasurer
[phone] [phone] [phone]
Compliance Data
Comments: /
Inspection Date 09/15/2020
Inspector's Name Jeffrey Nelson
v,� _ Operating Status Operating
Inspector's Signature:
Compliance Cade Compliance-inspection
Action Code FCE
pt�Date of Signature: 3�I2 U On-Site Inspection Result Compliance
__ DD
Total Actual emissions in TONSIYEAR:
TSP S02 NOX VOC CO PM10 * HAP
2014 --- 16.47 --- --- 2728.11
2009 --- 6.17 --- --- 905.00
Highest HAP Emitted in ounds)
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

1. DIRECTIONS:
From FRO take highway 87 south toward Elizabethtown. In approximately 30 miles, take the
exit to the right for US 701 and take a left onto US 701; facility is approximately 100 yards on the
right.
2. SAFETY CONSIDERATIONS:
Glasses are required in all areas, whereas ear-plugs and hard hat only in fabrication and
assembly areas when machinery is operating. Be alert to fork-lifts and golf carts moving
around while on facility grounds.
3. FACILITY PROCESS/DESCRIPTION:
Taylor Manufacturing builds farm equipment, small metal storage buildings, ice houses, and
wood/coal burning water heaters. Taylor receives sheet metal and structural tubing. There are
different buildings for the fabrication, assembly/welding, and finishing of the products.The
permitted emission sources are six spray booths each about 8 ft by 15 ft, large enough to
accommodate products. Each paint booth has a large filter panel on the back wall. These booths
are used for the painting of products and the application of the insulating foam. The facility is
phasing out insulating foam and purchasing large pre-manufactured insulation sheets.
4. PERMITTED EMISSION SOURCES:
Em�ssson ' EmisslonSource �� �Control Control
)DeSerlji Sy tlOL Ste
lrl Tb y�.B¢�
. : ._=j Deser,�pt�4h.i
Paint spray booth with integral panel filters
ES 1 96 square feet of filter area N/A Y N/A
� Not Operating;
Paint spray booth with integral panel filters
ES2 96 square feet of filter area N/A N/A
Not Operating;
Paint spray booth with integral panel filters
ES3 96 square feet of filter area N/A N/A
Not Operating;
Paint spray booth with integral panel filters
ES4 156 square feet of filter area N/A N/A
Not Operating;
Paint spray booth with integral panel filters
ES5 156 square feet of filter area N/A FN/A
Not Operating;
Paint spray booth with integral panel filters
ES6 156 square feet of filter area N/A N/A
Not Operating;
5. INSPECTION CONFERENCE:
On 15 September 2020, I Jeff Nelson of FRO DAQ conducted a compliance inspection of the
Taylor Manufacturing facility. I met with Ms. Denise Bridgers, Secretary Treasurer. We
discussed the following:

a) Verified the FACFINDER: no changes needed.
b) We reviewed the records for VOCs, HAPs, and TAPS. I inquired about the drop in
emissions and Ms. Bridgers stated that production has decreased significantly and that
painting has become a seasonal activity at the facility, in addition to the low production
during COVID-19.
c THROUGHPUTS:
Year VOC,TPY Total HAPs, Largest HAPs, HAP type
TPY TPY
2019 1.46 0.15 0.12 Toluene
2018 1.24 0.13 0.11 Toluene
2017 2.6 0.27 0.23 Toluene
2016 12.1 2.3 1.2 X lene
2015 13.3 3.0 1.6 X lene
2014 16.5 1.8 1.4 Toluene
6. INSPECTION SUMMARY:
Mr. Charles King,Plant Manager, led us down to the building where all of the paint booths are
housed. Each paint booth is very large and seemed well maintained. I inquired about the
frequency of filter changes. Mr. King stated that the facility's painter changes the filters at a
minimum every month and if he is painting a lot he will change them more frequently. Currently,
the facility is only using one of the paint booths. We then went around to the back of the building
to view the emission points. We did not observe any evidence of excess emissions on the stacks,
side of the building or on the ground.
7. PERMIT STIPULATIONS:
A.2 21) 0202—"Permit Renewal and Emission Inventory Reauirement"—At least 90 days
prior to the expiration date of this permit,the Permittee shall submit the permit renewal
application and air pollution emission inventory.
APPEARED IN COMPLIANCE—The permit renewal package was due by 31 January 2016
and was received on 21 January 2016. Next permit renewal will be due in November 2023 for
the 2022 calendar year.
A.3 2D .0515 PARTICULATE CONTROL REQUIREMENT—Particulate matter emissions
from the emission sources shall not exceed allowable emission rates.
APPEARED IN COMPLIANCE—Compliance was determined during the most recent permit
review based on operating the source as described in the permit conditions. No changes have
been made to operations since that determination.
A.4 2D 0521 VISIBLE EMISSIONS CONTROL REOUIREMENT—Visible emissions from
the emission sources manufactured after July 1, 1971, shall not be more than 20 percent opacity
when averaged over a six-minute period.
APPEARED IN COMPLIANCE—No emission sources were being operated at the time of
inspection. I did not observe any accumulation of emissions at exhaust points.
A.5 2D .0535 "Notification Requirement,"The facility is required to notify DAQ if excess
emissions occur for more than a 4-hour period caused by a breakdown or other abnormal
condition.

APPERARED IN COMPLIANCE—Ms. Bridgers and Mr. King stated there have been no
occurrences of excess emissions since the last inspection.
A.6 2D. .0540 "PARTICULATES FROM FUGITIVE DUST EMISSION SOURCES,"—The
Permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive
complaints or excess visible emissions beyond the property boundary.
APPEARED IN COMPLIANCE-I did not observe any accumulated dust emissions on the
surrounding property or at the entrance/exit access roads. The facility grounds are paved, except
for a dirt/gravel customer parking lot. Ms. Bridgers stated no dust complaints have been received
at the facility and no dust complaints have been received by FRO regarding this facility.
A.7 2D .0958(c)WORK PRACTICES REOUIREMENTS—As required by 15A NCAC 2D
.0958(c), for all sources at facilities that use volatile organic compounds(VOC)as solvents,
carriers, material processing media, or industrial chemical reactants, or in similar uses that mix,
blend, or manufacture volatile organic compounds, or emit volatile organic compounds as a
product of chemical reactions;the Permittee shall adhere to the following required work
practices:
i. The Permittee shall store all VOC-containing material not in use(including waste material) in
containers covered with a tightly fitting lid that is free of cracks,holes, or other defects.
ii. The Permittee shall clean up spills as soon as possible following proper safety procedures.
iii.The Permittee shall store wipe rags in closed containers.
iv. The Permittee shall not clean sponges, fabric,wood, paper products, and other absorbent
materials.
v. The Permittee shall drain solvents used to clean supply lines and other coating equipment into
closable containers and close containers immediately after each use.
vi. The Permittee shall clean mixing, blending, and manufacturing vats and containers by adding
cleaning solvent, closing the vat or container before agitating the cleaning solvent.
vii. The Permittee shall pour spent cleaning solvent into closable containers and close containers
immediately after each use.
b. As required by 15A NCAC 2D .0958(d), when cleaning parts with a solvent containing a
volatile organic compound,the Permittee shall:
i. flush parts in the freeboard area,
ii.take precautions to reduce the pooling of solvent on and in the parts,
iii. tilt or rotate parts to drain solvent and allow a minimum of 15 seconds for drying or until all
dripping has stopped,whichever is longer,
iv. not fill cleaning machines above the fill line,
v. not agitate solvent to the point of causing splashing.
APPEARED IN COMPLIANCE—The facility appears to be continuing with good work
practices regarding storage and clean up of VOC containing materials.

A.820 0711 TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT—
Pursuant to 15A NCAC 2Q .0711 "Emission Rates Requiring a Permit," for each of the below
listed toxic air pollutants(TAPS),the Permittee has made a demonstration that facility-wide
actual emissions,where one or more emission release points are obstructed or non-vertically
oriented, do not exceed the Toxic Permit Emission Rates(TPERs) listed in 15A NCAC 2Q
.0711(a). The facility shall be operated and maintained in such a manner that emissions of any
listed TAPS from the facility, including fugitive emissions,will not exceed TPERs listed in 15A
NCAC 2Q .0711(a).
a. A permit to emit any of the below listed TAPs shall be required for this facility if actual
emissions from all sources will become greater than the corresponding TPERs.
b. PRIOR to exceeding any of these listed TPERs,the Permittee shall be responsible for obtaining
a permit to emit TAPS and for demonstrating compliance with the requirements of 15A NCAC
2D .1100 "Control of Toxic Air Pollutants".
c. In accordance with the approved application,the Permittee shall maintain records of
operational information demonstrating that the TAP emissions do not exceed the TPERs as listed
below:
Point au 'M,ql `�„ alr CCbronic Poxioa nts Ac�fe Sy�st mic t ' ;' cute Irritc�tsr
bs/,daY l,' T011.
T bs/tif a 3
3
MEK(methyl ethyl 78 22.4
ketone)(78-93-3)
Styrene(100-42-5) 2.7
Toluene (108-88-3) 98 14.4
Xylene(mixed 57 16.4
isomers)(1330-20-7
APPEARED IN COMPLIANCE—Compliance was determined during the most recent permit
review based on operating the source as described in the permit conditions. No changes have
been made to operations since that determination.
A.9 20 .0803 EXCLUSIONARY RULE REQUIREMENTS -The Permittee shall limit total
VOCs, greatest HAP, and total HAPs emissions,respectively to less than 100/10/25 TPY and
submit an annual report by 1 March for the previous year's emissions.
APPEARED IN COMPLIANCE—The annual report for CY 2019 was received 9 March 2020
and reported: Total VOCs— 1.46 Tpy; Greatest HAPs(toluene)—0.12 Tpy; and Total HAPs—
0.15 Tpy.
8. NON-COMPLIANCE HISTORY SINCE 2010:
3-12-2020 NOV for late reporting
3-20-2018 NOD for late reporting.
2-14-2014 NOD: Failure to Operate and Maintain spray booth filters in ES-2 and ES-3.

9. 112R STATUS:
This facility does not store any of the listed chemicals above the threshold quantities, and is not
required to maintain a written Risk Management Plan(RMP).
10. CONCLUSIONS/RECOMMENDATIONS:
Taylor Manufacturing appeared to be in compliance with the conditions in the facility's current
air permit on 15 September 2020.
Pink Sheet:
Recommend removing the 213 .0958 stip during upcoming permit renewal since the recent legislative
change makes it applicable only in non-attainment and maintenance areas and this county is in attainment.
Recommend evaluating VOC/HAP emissions to see whether the 2Q .0803 permit condition needs to
remain in the permit. If removed,this would also remove the annual report requirement.
/j In