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HomeMy WebLinkAboutAQ_F_1300029_20201204_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office AIR QUALITY Galvan Industries,Inc. NC Facility ID 1300029 Inspection Report County/FIPS: Cabarrus/025 Date: 12/4/2020 Facility Data Permit Data Galvan Industries,Inc. Permit 03639/R15 7320 Galvan Way Issued 4/20/2017 Harrisburg,NC 28075 Expires 3/31/2025 Lat: 35d 18.8514m Long: 80d 40.8726m Class/Status Small SIC: 3479/Metal Coating And Allied Services,nec Permit Status Active NAICS: 332812/Metal Coating,Engraving(except Jewelry and Silverware),and Current Permit Application(s)None Allied Services to Manufacturers Program Applicability Contact Data SIP Facility Contact Authorized Contact Technical Contact Harshad Londhe Harshad Londhe Laurens Willard Plant Manager Plant Manager President (704)455-5102 (704)455-5102 (704)455-5102 Compliance Data Comments: Inspection Date 12/04/2020 Inspector's Name Karyn Kurek Inspector's Signature: Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 * HAP 2015 1.45 0.0100 1.58 0.0900 1.32 1.45 56.80 2011 4.42 0.0200 3.05 0.1700 2.55 4.42 --- 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 Galvan Industries Inc. December 4,2020 Page 2 of 9 Type Action: X Full Compliance _Partial Compliance _Complaint Other: Evaluation Evaluation/Reinspection Investigation Data Date submitted for initial review: 12/04/2020 X IBEAM WARNING/OB,NOD,NOV,NRE Tracking: X IBEAM Document IBEAM Inspection,list date inspected X IBEAM LAT/LONG,Facility Locked IBEAM Inspection,list date draft is submitted X IBEAM LAT/LONG,Coordinates checked IBEAM Inspection,pollutants/programs checked IBEAM Complaint X_IBEAM Planning,Next Inspection Date 12/01/2021 Directions to Facility: Travel from Mooresville to Concord via Highway 3 South;turn right on Odell School Road;turn left on Poplar Tent Road; travel Interstate 85 South; exit off Interstate 85 South onto Exit #48-Interstate 485 South to Rock Hill; exit off Interstate 485 South at Exit#33-Harrisburg(Highway 49); turn left off exit ramp onto University City Boulevard(Highway 49 North); after approximately 1.8 miles turn right onto Galvan Road(also shown as Millbrook). The street address of this office is 7315 Millbrook Road which is directly across the street. Prior to conducting the inspection at this facility,the inspector should check in with the Office. The facility is located at 7320 Millbrook Road. Safety Equipment: The facility requires safety shoes, safety glasses and hardhat be worn. A safety vest is highly recommended due to forklift traffic. Safety Issues: Be mindful of forklift traffic. The dip tanks and the kettle require attention when near them. Lat/Long Coordinates: A review of the facility's coordinates on DAQ's"Facilities Regulated by Air Quality"website indicates the facility latitude and longitude coordinates are not listed;however,the location appears to be accurate.No changes to the latitude and longitude coordinates of this facility in IBEAM are needed.In addition, latitude and longitude coordinates of this facility are locked in IBEAM. Email contacts: The facility contacts were reviewed.Mr. Laurens Willard's title was changed to President within IBEAM. COVID-19 Information:- - Did you complete the DEQ COVID Screening Questionnaire on the day you conducted an on-site facility inspection and based on the responses were you able to safely report to the worksite? Yes,the morning of Dec. 4,2020 prior to leaving for the inspection and I was cleared to report t the site. - Who did you speak with regarding the facility's COVID-19 inspection procedures? (name/title/phone number)An email was sent Dec. 3,2020 to Mr. Londhe. - Does the facility allow on-site inside the facility buildings, on-site but outside only or virtual only inspections?The facility is not allowing onsite access due to Covid. - Does the facility follow social distancing,mask wearing and hand washing procedures in the facility? (list other procedures the facility follows)The facility is not allowing onsite access due to Covid. Galvan Industries Inc. December 4,2020 Page 3 of 9 - Are there any COVID-related requirements of inspectors before entering the facility? (temperature check, sign health form, etc)The facility is not allowing onsite access due to Covid. - What type of inspection did you perform? (on-site in the buildings, on-site outside only,virtual) A records request conducted virtually,and the onsite portion was conducted via a drive-by.I arrived at the facility Friday, December 4, 2020 at approximately 8:55 AM. Due to Covid restrictions, I emailed the facility with a records request on Dec3, 2020, conducted the visual inspection via a drive by since all emission sources vent outside and I am familiar with the locations of them. - If the facility allows on-site,in the building inspections and you chose not to conduct an inspection inside then clarify why. The facility is allowing access due to Covid. 1. General Information: The purpose of this site visit was to conduct a routine air quality inspection. This company uses zinc to galvanize steel and iron for the construction industry.The galvanizing process involves shot blasting,cleaning and degreasing with sodium hydroxide and sulfuric acid, pre-fluxing with a mixture of zinc chloride and ammonium chloride, and zinc coating of iron and steel products in a kettle to provide protection to the metal against corrosion. Galvan Industries,Inc. is a sulfuric acid dry flux galvanizing facility. The facility operates three eight-hour shifts,five days per week,fifty-two weeks per year.I arrived at the facility Friday,December 4,2020 at approximately 8:55 AM.Due to Covid restrictions,I emailed the facility with a records request on Dec 3,2020, conducted the visual inspection via a drive by since all emission sources vent outside and I am familiar with the locations of them. 2. Facility Contact Information: The facility contacts were reviewed. Mr. Laurens Willard's title was changed to President within IBEAM. 3. Compliance history file review: As the result of a July 2018 complaint investigation,this office instructed the facility,via a memo dated July 31,2018,to review their operations and consider additional measures to minimize their particulate emissions. At the time of this inspection, all of the deliverables below have been completed by the facility. They stated they are committed to ensuring compliance with all requirements and details are provided below: • Galvan has removed approximately 1,000 tons of dirt silt from across 62,000 square feet of gravel area around the facility in an effort to reduce dust/particulate emissions. In addition, forklifts traveling in these areas will reduce speed to minimize dust from being stirred up. The facility continues to maintain these areas and conducts wet suppression of the surface area to reduce dust. During this inspection the grounds were recently treated with water and were observed to be wet. A bagfllter has been installed on the galvanizing building to capture some of the particulate emissions from the galvanizing process. Due to the product flow through the galvanizing building, some of the emissions are not captured by the bagfllter and, as a result,were vented through roof top fans. To increase the capture efficiency of the bagfllter,the roof top fans on the galvanizing building Galvan Industries Inc. December 4,2020 Page 4 of 9 have been turned off and remain turned off as per Mr. Londhe. In addition,the capture efficiency of the bagfilter has been increased by reducing the gaps associated with the galvanizing fume enclosure. The facility evaluated an additional bagfilter design option to increase efficiency,however that design could not withstand the high temperatures associated with their process. The facility is investigating an alternate design option as discussed during this inspection. • Increase effectiveness of fume enclosure doors by improving employee work methods. This was further discussed during this inspection with Mr. Londhe and Mr. Willard. Compliance assistance was offered with respect to documenting the training of these work methods,refresher training,new employee training and operational checklists for periodic walk throughs to check the areas of concern. The facility was very open to these suggestions and agreed to look into continuous improvement initiatives. The addition of translucent siding to the pickle tank building to contain steam and increase entrainment has been completed and the tanks were observed in operation at the time of inspection with no odors or visible emissions other than steam. • Galvan has completed the analysis of various fume suppressants for the cleaning baths to assist with minimizing emissions. Galvan has been using the fume suppressant since February 22,2019 and is using a product called WIM 2X. 4. Observations of permitted air emission sources and control devices: Emission Emission Source Control Control System Source ID I Description System ID Description natural gas/propane-fired hot dip zinc galvanizing kettle(3.0 million Btu GK-1 per hour maximum heat BH-2 bagfilter(5,340 square input; 14,000 pounds per feet of filter area) hour maximum process rate; 42 feet x 4.5 feet x 8.5 feet that uses a dry galvanizing system) Blocks of zinc are melted and heated to 840 degrees Fahrenheit by 32 burners(16 burners on one side and 16 burners on the other side of the kettle). These burners heat bricks,which radiate heat to the kettle. Roughly 6,000 pounds of zinc per day are used to coat various metal products. Observed: The kettle(ID No. GK-1)and bagfilter(ID No. BH-2)were observed in operation at the time of inspection with no visible emissions or odors noted. shot blasting machine bagfilter(3,500 square SBM-1 (14,350 pounds per hour 131-1-1 feet of filter area) maximum process rate) In the blast building of this facility, a shaker type bagfilter is installed on a shot blasting machine. The machine uses steel shot as a blast medium to remove rust from the surface of metal prior to being galvanized. Observed: The shot blasting machine (ID No. SBM-1) and bagfilter (ID No. BH-1) were observed in operation at the time of the inspection with no visible emissions or odors noted. Galvan Industries Inc. December 4,2020 Page 5 of 9 5. Observations of insignificant air emission sources and control devices listed on the current permit: Source I Observed IEX-1 -sodium hydroxide(NaOH)tank This was not observed at the time of (8,500-gallon capacity) inspection due to Covid restrictions. IEX-2 -sulfuric acid tank This was not observed at the time of (14,100-gallon capacity) inspection due to Covid restrictions. IEX-5 -zinc chloride/ammonium chloride pre- This was not observed at the time of flux tank(8,400-gallon capacity) inspection due to Covid restrictions. IEX-6 -water rinse tank This was not observed at the time of (14,100-gallon capacity) [inspection due to Covid restrictions. IEX-7 -water rinse tank This was not observed at the time of (9,700-gallon capacity) inspection due to Covid restrictions. IEX-8 -water quench tank This was not observed at the time of (I8,000-gallon capacity) inspection due to Covid restrictions. IEX-9 -natural gas/propane-fired boiler This was not observed at the time of (8.4 million Btu per hour maximum heat input) inspection due to Covid restrictions. IEX-3 -sulfuric acid tank This was not observed at the time of (14,1 00-gallon capacity) inspection due to Covid restrictions. IEX-4 -sulfuric acid tank This was not observed at the time of (14,1 00-gallon capacity) inspection due to Covid restrictions. IEX-11 -sulfuric acid tank This was not observed at the time of (5,000-gallon capacity) inspection due to Covid restrictions. IEX-12 -propane storage tank This was not observed at the time of (18,000-gallon capacity) inspection due to Covid restrictions. IEX-13 -process water tank This was not observed at the time of (16,000-gallon capacity) inspection due to Covid restrictions. IEX-14 -countercurrent liquid impingement packed tower type wet scrubber in series with an The scrubber was observed at the time integral chevron type mist eliminator of inspection with no issues noted and (8.7 square feet of filter area; 40 gallons per is being inspected on an annual basis. minute minimum liquid injection rate)installed The facility is keeping records of the on a copper electroplating process inspections. rIEX-15 -sodium hydroxide(NaOH)tank This was not observed at the time of gallon capacity) inspection due to Covid restrictions. 6. Observations of air emission sources and control devices not listed on the current permit: None. 7. Compliance with specific permit conditions and limitations: Galvan Industries Inc. December 4,2020 Page 6 of 9 A. Specific Condition and Limitation No. A. 2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT -The Permittee, at least 90 days prior to the expiration date of this permit, shall request permit renewal by letter in accordance with 15A NCAC 2Q .0304(d) and(f). Pursuant to 15A NCAC 2Q .0203(i),no permit application fee is required for renewal of an existing air permit(without a modification)request. The report shall be submitted to the Regional Supervisor,DAQ and shall document air pollutants emitted for the 2023 calendar year. Observed: The current permit 03639R15 was issued April 20,2017 and does not expire until March 31,2025. Compliance with this stipulation is indicated. B. Specific Condition and Limitation No.A. 3. "PARTICULATE CONTROL REQUIREMENT" In accordance with 15A NCAC 2D .0403,no facility or source of air pollution shall cause any ambient air quality standard to be exceeded. The ambient air quality standards for total suspended particulate matter shall not exceed 75 micrograms per cubic meter annual geometric mean, and the 150 micrograms per cubic meter maximum 24-hour concentration shall not be exceeded more than once per year. The Permittee must resurface its back lot(scraping and gravelling as necessary) every six months. Records of all resurfacing activities shall be recorded in the logbook. The logbook shall be kept on-site and made available to DAQ personnel upon request. Observed: The facility is keeping records of resurfacing activities; the onsite records are labeled "yard maintenance sign off'.The most recent resurfacing since the last inspection occurred Oct. 1, 2019,Feb. 18,2020, Sept. 10,2020(invoice for work performed in August 2020)and Oct. 6,2020 (this work was rework done, not a complete resurface). The facility was notified via email dated Dec. 21, 2020 that the next resurfacing would be required 6 months from the Sept. 10, 2020 date. Compliance with this stipulation is indicated. C. Condition A.4. "Particulate Control Requirement" as required by 15A NCAC 2D .0515 "Particulates from Miscellaneous Industrial Processes", states that particulate matter emissions from hot dip zinc galvanizing kettle (ID No. GK-1) shall not exceed allowable emission rates. Observed: The allowable emission rates from this facility are not expected to be exceeded and were assessed during the permit review process April 20,2017. Compliance with this stipulation is indicated. D. Specific Condition and Limitation No. A. 5. "Sulfur Dioxide Control Requirements" As required by 15A NCAC 2D .0516 "Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the combustion sources shall not exceed 2.3 pounds per million Btu heat input. Observed: The allowable emission rates from this facility are not expected to be exceeded and were assessed during the permit review process April 20,2017. Compliance with this stipulation is indicated. E. Specific Condition and Limitation No. A. 6. "Control of Visible Emissions" states that the visible emissions from the emission sources, manufactured after July 1, 1971, are limited to 20 percent opacity when averaged over a six-minute period. Observed: No visible emissions from this facility were observed at the time of the inspection. Compliance with this stipulation is indicated. Galvan Industries Inc. December 4,2020 Page 7 of 9 F. Specific Condition and Limitation No. A. 7. "Notification Requirement" as required by NCAC21) .0535, the Permittee of a source of excess emissions that last for more than four hours and that results from a malfunction, a breakdown of process or control equipment or any other abnormal conditions, shall notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time of the Division's next business day of becoming aware of the occurrence. Observed: No excess emissions resulting from a malfunction, breakdown of process or control equipment or any other abnormal condition has occurred since the last inspection.Compliance with this stipulation is indicated. G. Specific Condition and Limitation No. A. 8. "FUGITIVE DUST CONTROL REQUIREMENT" As required by 15A NCAC 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. Observed: The facility uses a water distributor to control excessive dust. No fugitive dust was observed at the time of inspection. Compliance with this stipulation is indicated. H. Specific Condition and Limitation No. A. 9. "CONTROL OF EMISSIONS FROM ABRASIVE BLASTING" -As required by 15A NCAC 2D .0541 "Control of Emissions from Abrasive Blasting," The owner or operator of shot blasting machine(ID No. SBM-1) shall: - ensure that any abrasive blasting operation conducted outside a building or conducted indoors and vented to the atmosphere is performed in accordance with the requirements set forth in 15A NCAC 2D .0521, Control of Visible Emissions. For the purposes of this Rule,the visible emissions reading for abrasive blasting performed outside a building shall be taken at a spot approximately one meter(3.3 feet)above the point of abrasive blasting with a viewing distance of approximately five meters (16.4 feet); - conduct all abrasive blasting operations within a building except under one or more of the following conditions: ■ when the item to be blasted exceeds eight feet in any dimension, ■ when the surface being blasted is situated at its permanent location or not further away from its permanent location than is necessary to allow the surface to be blasted; — for any abrasive blasting operation conducted outside a building,take appropriate measures to ensure that the fugitive dust emissions created by the abrasive blasting operation do not migrate beyond the property boundaries in which the abrasive blasting operation is being conducted. Observed: Shot blasting operations are conducted indoors and vented through the associated 3,500 square feet of filter area bag filter(ID No. BH-1). The shot blaster bagfilter was observed in operation at the time of inspection with no issues noted. The facility confirmed the shotblaster was in operation,all sources were operating at the time of inspection. Compliance with this stipulation is indicated. I. Specific Condition and Limitation No. A.10. FABRIC FILTER REQUIREMENTS including cartridge filters,baghouses,and other dry filter particulate collection devices-As required by 15A Galvan Industries Inc. December 4,2020 Page 8 of 9 NCAC 2D .0611, particulate matter emissions shall be controlled as described in the permitted equipment list. The Permittee shall perform, at a minimum, an annual (for each 12-month period following the initial inspection) internal inspection of each bagfilter system. In addition, the Permittee shall perform periodic inspections and maintenance as recommended by the equipment manufacturer. The results of all inspections and any variance from manufacturer's recommendations or from those given in this permit (when applicable) shall be investigated with corrections made and dates of actions recorded in a logbook. Records of all maintenance activities shall be recorded in the logbook. Observed: A logbook of maintenance and inspections for bagfilters BH-1 and BH-2 was maintained and sent via an email request for records(see table below).The facility conducts internal maintenance on both of the bagfilters and also pays to have the vendor of the kettle bagfilter (ID No.BH-2)come onsite to ensure continued proper operations as noted below;this practice is above and beyond the permit requirement and was completed May 22, 2020. Compliance with this stipulation is indicated. Emission Source Previous Inspection(s) Most Recent Inspections Kettle(131-1-2) 10/20/2018-vendor onsite 11/14/2020 11/2/2018 11/11/2020 11/11/2018 5/9/2020 5/3/2019-vendor onsite 5/22/2020-vendor onsite 5/8/2019 4/25/2020 6/5/2019 4/14/2020 6/13/2019 3/23-3/28/2020 6/24/2019 1/25/2020 10/27/2019 Shot Blasting(131-1-1) 4/17/2018 4/16/2020 7/2/2018 10/27/2019 10/27/2018 J. Specific Condition and Limitation No. A. 11. "CONTROL AND PROHIBITION OF ODOROUS EMISSIONS" The Permittee shall not operate the facility without implementing management 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. Observed. No odors were detected beyond the facility boundary at the time of inspection. Compliance with this stipulation is indicated. 8. Summary of changes needed to the current permit: None. 9. Compliance assistance offered duringthe he inspection: The work methods for increased effectiveness of the fume enclosure doors was further discussed during this inspection with Mr.Londhe and Mr.Willard. Compliance assistance was offered with respect to documenting the training of these work methods,refresher training,new employee training and operational checklists for periodic walk throughs to check the areas of concern. The facility was very open to these suggestions and agreed to look into continuous improvement initiatives. 10. NSPS/NESHAP Review Galvan Industries Inc. December 4,2020 Page 9 of 9 The facility does not have any generators therefore it is not subject to NESHAP 4Z. The facility does not have any boilers therefore it is not subject to NESHAP W. The facility does not have any gasoline storage tanks onsite;therefore,it is not subject to NESHAP 6C. 11. Section 112(r) applicability: This facility does not appear to be subject to the requirements of the Chemical Accident Release Prevention Program, Section 112(r)of the Clean Air Act. 12. Compliance determination: Based on my observations during this inspection,this facility appeared to be in compliance with the applicable air quality regulations. KAK:Ihe cc: MRO File https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/CABARRUS/00029/INSPECT 20201204.docx