AQ_F_0200088_20191204_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Triumph Insulation Systems,LLC
NC Facility ID 0200088
Inspection Report County/FIPS:Alexander/003
Date: 12/04/2019
Facility Data Permit Data
Triumph Insulation Systems,LLC Permit 08934/R06
138 Wittenburg Industrial Drive Issued 4/2/2018
Taylorsville,NC 28681; Expires 3/31/2026
Lat: 35d 50.2770m Long: 8ld 10.7682m Class/Status Synthetic Minor
SSIC: 3497/Metal Foil And Leaf Permit Status Active
NAICS: 322225/Laminated Aluminum Foil Manufacturing for Flexible Current Permit Application(s)None
Packaging Uses
Program Applicability
Contact Data
SIP
Facility Contact Authorized Contact Technical Contact
Keith Hertzler Wayne Cassidy Keith Hertzler
EHS Manager Plant Manager EHS Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 12/04/2019
Inspector's Name Jim Vanwormer
Inspector's Signature: v( p m � Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: ]31 f On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2018 0.0200 --- 0.4300 1.14 0.0700 0.0200 1706.96
2017 0.0300 --- 0.5100 1.31 0.0800 0.0300 2053.70
*Highest HAP Emitted inpounds)
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) Sources?Tested

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Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 12/5/2019 _IBEAM INFO,WARNING/OB,NOD,NOV,NRE
Tracking: X IBEAM Document
X IBEAM Inspection,list date inspected X IBEAM LAT/LONG,Facility Locked
X IBEAM Inspection,list date draft is submitted X IBEAM LAT/LONG,Coordinates checked
X IBEAM Inspection,pollutants/programs checked _IBEAM Complaint
X IBEAM Planning,Next Inspection Date_12/1/2020
Directions: Take I-77 north, 1-40 west, and go north on NC 16 (from exit #132). Take a right onto
Wittenburg Road (at traffic signal, across from Friendship Church Road). Turn right onto Wittenburg
Industrial Drive. The facility is located at the end of the street on the right.
Safety Equipment. Safety shoes and safety glasses are required.
Safety Issues:None noted.
Lat/Long: A review of the facility's coordinates on "Maps of DAQ Regulated Facilities" indicates the
facility's latitude and longitude coordinates are accurate.
Email Contacts:No changes are necessary at this time.
1. General Information. The purpose of this site visit was to conduct an Air Quality compliance inspection.
The inspector, along with Ms. Emily Supple, arrived at the facility at 9`:15 am on December 5,2019.
Mr.Keith Hertzler,Environmental Manager, accompanied us on the inspection. This facility
manufactures fire retardant laminate used primarily in transportation systems(aircraft,boats). This
laminate is a layer between the outer surface and insulation designed to prevent fire from spreading and is
designed to withstand a 2000-degree F flame for a certain time period. The facility is now operating'16
hours per day, 5 days per week, 51 weeks per year.The facility has 16 employees at this time.
2. File Review.
A. Contacts. The facility contact list was checked and there were no changes were
submitted for data input. The information in IBEAM is current.
B. Files. The following files were reviewed prior to the inspection: previous inspection
reports; correspondence since the last inspection; etc.
C. Compliance history:
The facility has not had any compliance issues in the last five years.
D. Operating Conditions established by Stack Testing. A stack test was conducted on
October 24,2017 to document RTO efficiency.

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E. NSPS/NESHAP Review
The facility is not subject to NESHAP 6C because they do not have gasoline storage tanks. The
facility is not subject to any other NSPS or NESHAP regulations at this time.
3. Observations of permitted air emission sources and control devices:
Emission Emission Source ' Control Control System
Source ID Description System ID Description
_ _
ES01,ES02 propane-fired laminator CDO1 propane-fired
(ID No. ES01; 4.8 `' 'regenerative thermal
million Btu per hour oxidizer(3.0 million Btu
maximum heat input rate) per hour heat input rate)
and mixing room(ID No.
ES02)
Observed. This equipment was in operation during the inspection with no issues noted.
4. Observations of insignificant air emission sources and control devices listed on the current
ep rmrt:
Source Exemption Source of Source of Title V
Regulation TAPs? Pollutants?
p p p ( - _ -
p input)
2Q .0102 No Yes
IES-1 -propane-fired space heater 65;000 .
Btu per hour heat in ut (g)(5)(A)
IES-2 -propane-fired space'heater(65,000 2Q .0102 No Yes
Btu per hour heat input) (g)(5)(A)
IES-3 -propane-fired space heater(65,000 2Q .0102 ( No Yes
Btu per hour heat input) (g)(5)(A) 1
IES-4-propane-fired space heater,(45,000 2Q .0102 No Yes
Btu per hour heat input)` _ _._ _ :(g)(5)(A)._.
IES-5 -propane-fired space heater(45,000 �2Q .0102 No Yes
Btu per hour heat input) (g)(5)(A)
Observed. The comfort heat space heaters were observed during the inspection. They were operating
with no issues noted.
5. Observations of air emission sources and control devices not listed on the current permit:
The facility has two insignificant sources based on the scale of activity.
• The facility has a 150 foot per minute printer which is ducted to the oxidizer.
• The facility has a small MEK distiller which is ducted to the oxidizer.
These items were previously added to the yellowsheet.The printer was not operating during the
inspection..'

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6. Compliance with specific permit conditions and limitations:
a. Condition A.2. A NCAC 2Q .0304(d)and(f)"Permit Renewal and Emission Inventory"The
Permittee, at least 90 days prior to the expiration date of this permit. The report shall be
submitted to the Regional Supervisor,DAQ and'shall document air pollutants emitted for the
2024 calendar year.
Observed. The permit expires on March 31,2026. No further action is required at this time.
b. Condition A.3 15A NCAC 2D .0516 "Sulfur Dioxide Emissions from Combustion Sources,"
sulfur dioxide emissions from propane-fired laminator(ID No.ES01)shall not exceed 2.3 pounds
per million Btu heat input.
Observed. Per MRO memo "21) .0516 analysis" dated 04/10/97, compliance is indicated for No.
1 fuel oil,No. 2 fuel oil, natural gas, butane, propane, and wood dust. The facility uses primarily
natural gas and No.2 fuel oil as a backup. Compliance is indicated. .
c. Condition A.4 15A NCAC 2D .0521 "Control of Visible Emissions,"visible emissions from the
emission sources, manufactured after July 1, 1971, shall not be more than 20 percent opacity.
However, sources which must comply with a visible emissions standard in 15A NCAC 2D .0524
"New Source Performance Standards" or .1110"National Emission Standards for Hazardous Air
Pollutants" shall meet that standard instead of the 2D .0521 visible emissions standard.
Observed. The facility was operating during the inspection. No visible emissions were
observed at the facility. Compliance is indicated.
d. Condition A.5. 15A NCAC 2D .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 MRO of any such occurrence by 9:00
am the next business day.
Observed. No excess emissions were experienced during the past year. Compliance is indicated.
e. Condition A.6. 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. No complaints of fugitive dust or visible emissions have been reported since the last
inspection. Compliance is indicated.
f. Condition A.7. 15A NCAC 2D .0605 "Compliance Certification",the Permittee shall submit a
compliance certification to the DAQ and the EPA. The certification shall encompass the current
calendar year from January I"to the effective date of permit 08934R06 (April 2,2018). The
certification will verify that the facility was meeting all of the conditions of the Title V permit at
the time of the permit change.
Observed: The facility submitted a compliance certification on April 20,2018 for the January to
March 30,2018 time period. Compliance is indicated.

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g. Condition A.8. 15A NCAC 2D .1806 "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 objectionable odors were detected beyond the facility boundary. Compliance is
indicated.
h. Condition A.9. 15A NCAC 2Q .0315 "Synthetic Minor Facilities,"to avoid the applicability of
15A NCAC 2Q .0501 "Purpose of Section and Requirement for a Permit," facility-wide emissions
shall be less than the following:
Pollutant Emission Limit
,(Tons per consecutive 12-month period)
Individual HAPs( 10
C Total HAPs 25
a. Inspection and Maintenance Requirements—
i. Thermal Oxidizer Requirements-Emissions shall be controlled as described in
the permitted equipment list.To comply with the provisions of this permit and
ensure that emissions do not exceed the regulatory limits,the Permittee shall
perform periodic inspections and maintenance(I&M) as recommended by the
manufacturer.As a minimum,the Permittee shall perform an annual(for each 12
month period following the initial inspection) internal inspection of each primary
heat exchanger and associated inlet/outlet valves to ensure structural integrity.
b. Monitoring Requirements—
i. Thermal Oxidizer Requirements-The Permittee shall ensure the proper
'performance of each thermal oxidizer by monitoring the following operational
parameters:
A. The Permittee shall continuously record the temperature measured inside
the second half of the oxidizer(away from the flame zone)with a
minimum temperature of 1600 degrees Fahrenheit.
B. The Permittee shall record the flow rate to the oxidizer(maximum flow .
rate of 15,000 scfin)once per week.
c. Recordkeeping Requirements
i. A log book shall be kept on site for thermal oxidizer(ID No. CDO1).
Observed. The facility is maintaining records of the Total HAP and Individual HAP emissions
for calendar year 2019 through November 2019. The facility reported emissions of 0.853 tons of
total HAPs for CY 2018. This quantity of total HAPs is well below the limit. The oxidizer was
operating with a chamber temperature of at 1615 °F during the inspection. The facility has been
conducting periodic inspections and maintenance on the oxidizer. Mr. Hertzler provided the

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required temperature and flow rate recordings on his computer. The previous internal inspections
of the oxidizer were April 29,2019 and October 18,2018. The flow rate to the oxidizer was 7931
scfm during the inspection. Compliance is indicated.
f. 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 21) .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:
Chronic Acute
I Carcinogens Acute Systemic
Pollutant Toxicants ! Irritants
t lb/y r Toxicants lb/hr E
�._ _____alb/day) _ -- _ ..� .. (lb/hr)
Ammonia(as NH3) (7664-41-7) �. ..._. ..._ _- ._. __.._0..68
Ethyl acetate(141-78-6) _ ... _. -. .-.36
MEK(methyl ethyl ketone,2-
78 22.4
butanone)(78-93-3)
Toluene(108-88-3) __ . _.. '.�. ...- _ -.- _.. 98 ._.. _ 14_4 -
Observed. The facility provided records that document the daily/hourly emissions of the above
TAPS. The level of emissions has not exceeded the TPER limits during the period reviewed from
November 2018 to October 2019. Compliance is indicated.
7. Summary of changes needed to the current permit:
None.
8. Compliance assistance offered during the inspection:
None noted.
9. Section 112(r) applicabilitX:
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.
i

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10. Compliance determination:
Based on my observations,this facility appeared to be in compliance'with the applicable air
quality regulations at the time of the inspection.
JRV:Ihe
c: MRO File
https://neconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00088/INSPECT 20191204.docx