AQ_F_1300156_20191218_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Cabarrus Plastics
NC Facility ID 1300156
Inspection Report County/FIPS:Cabarrus/025
Date: 12/1.8/2019
Facility Data Permit Data
Cabarrus Plastics Permit 09725/R03
2845 Armentrout Drive Issued 3/24/2016
Concord,NC 28025 Expires 2/29/2024
Lat: 35d 22.5906m Long: 80d 34.7100m Class/Status Small
SIC: 3089/Plastics Products,Nec Permit Status Active
NAICS: 326199/All Other'Plastics Product Manufacturing Current Permit Application(s)None
Contact.Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Anthony Woodruff Mike Langefeld Don Burchett
Quality Manager Plant Manager Quality Engineer
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 12/18/2019
Inspector's Name Jim Vanwormer
Inspector's Signature: P� (��_ _(, Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: h l� On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2015 --- --- --- 15.30 --- --- 2767.31
2010 --- --- ---
*Highest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

:f n.
Cabarrus Plastics
December 1.8,2019
Page-2—
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 12/20/2019 _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 12/01/21
Directions From MRO,take NC 3 to Odell School Road. Left onto NC-73. Turn right on Central Dr.
NW. Turn right onto Concord Parkway N. Turn left on to US-601 S. Turn right onto Armentrout Drive.
The facility is before the curve on Armentrout Drive,the large sign out front is for CVG.
Safety Equipment. Safety glasses are required by this facility. Safety shoes are recommended.
Safety Issues No specific safety issue was noted.
Lat/Lon2: 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: The emails for the Facility,Authorized and Technical contacts were verified.
1. The inspector arrived at the facility with co-inspector Emily Supple on December 18,2019 at
9:30 am. The purpose of this site visit was to conduct a routine air quality inspection.This
facility manufactures reinforced plastic parts for non-road and road vehicles. The process
involves various mold injection and spraying operations. Cabarrus Plastics currently employs
approximately 262 people.The facility is currently operating 16 hours a day and five days a
week, 51 weeks per year.There are 2 separate buildings that house paint booth operations. Mr.
Don Burchett,Quality Engineer and Mr. Anthony Woodruff,Quality Manager,accompanied us
during this inspection.
2. Facility Contact Information:
During the inspection I verified the facility contact information in IBEAM. The invoice contact
does not need to be changed.
3. Compliance history file review:
There have not been any violations in the last five years.
The current compliance status is discussed in the following sections.

Cabarrus Plastics
December 18,2019
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4. Observations of permitted air emission sources and control devices:
Emission Source ID Emission Source Description {'
*Note:No Control Devices at this facility I
I
ES-12,ES-13,ES-14,ES-15,ES-16 j five(5) dry-filter type paint spray booths for MCU process
Observed: One booth was in operation with no problems noted. All dry filters were in place and
appeared to be operating with no visible emissions.
ES-18,ES-19,ES-20, ES-21 four(4)dry-filter type paint spray booths for I-skin process
Observed: Two booths were in operation with no problems noted.All dry filters were in place and
appeared to be operating with no visible emissions.
dry-filter type paint spray booth for regrind process 1
Observed: This operation is no longer located at the facility.
i
ES-23 dry-filter type paint spray booth for structural rigid process
Observed: The booth was not in operation at the time of this inspection.All dry filters were in place !
and appeared to be operating with no visible emissions. I
ES-24,ES-25 two(2) dry-filter type paint spray booths for T-RIM process I
E
i
Observed: Four bays are considered to be two booths. The booths were not in operation during the
inspection. All dry filters-were in place and appeared to be operating with no visible emissions.
,
ES-26 dry-filter type paint spray booth for VCR process
t
Observed: The facility currently considers this booth to be double counting of other RIM process
booths where mold release is used.
ES-27 dry-filter type paint spray booth for IVCR process
I
Observed: Two bays are considered one booth which is located in the S-RIM process area. The booth
was in operation at the time of the inspection.All dry filters were in place and appeared to be operating
with no visible emissions.
ES-28 dry-filter type paint spray booth for the elastomeric process
a
Observed: The facility currently does not have an area for an elastomeric process.
5. Observations of insignificant air emission sources and control devices listed on the current
p 't. -

Cabarrus Plastics
December 18,2019
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N/A
6. Observations of air emission sources and control devices not listed on the current permit:
a. None noted.
7. Compliance with specific permit conditions and limitations:
a. Condition A.2.As required by 15A NCAC 2Q .0203(i)`Emission Inventory Requirement"
states that at'least 90 days prior to the expiration date of this permit,the Permittee shall
submit the air pollution emission inventory report for 2015 calendar year to MRO DAQ.
Observed. The facility received a new permit on March 24,2016. Compliance with this
stipulation is indicated.
b. Condition A.3.As required by 15A NCAC 2D .0515 "Particulates from Miscellaneous
Industrial Processes,"particulate matter emissions from the emission sources shall not exceed
allowable emission rates.
Observed. The allowable emission rates from this facility are not being exceeded.
Compliance with this stipulation was determined during the permit application process.
c. Condition A.4. 15A NCAC 2D .0521, "Control of Visible Emissions"The facility is limited
to 20 percent opacity.
Observed. No visible emissions were observed at the facility. Compliance with this
stipulation is indicated.
d. Condition A.5. 15A NCAC 2D .0535. 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. According to a conversation with Mr.Burchett,and a records review,no excess
emissions have occurred at the facility. Compliance with this stipulation 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.
c
Observed. No complaints have been received by this office and no fugitive dust was
observed during this inspection. Compliance with this stipulation is indicated.
f. Condition A.7. 15A NCAC 2D .0958 (c)"Work Practices for Sources of Volatile Organic
Compounds

Cabarrus Plastics
December 18,2019
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1. .The Permittee shall store all VOC-containing material notin use(including waste r'
material)in containers covered with a tightly fitting lid that is free of cracks,
holes, or other defects.
2. The Permittee shall clean up spills as soon as possible following proper safety
procedures.
3. The Permittee shall store wipe rags in closed containers.
4. The Permittee shall not clean sponges,fabric,wood,paper products, and other
absorbent materials.
5. The Permittee shall-drain solvents used to clean supply lines and other coating
equipment into closable containers and close containers immediately after each
use.
6. 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.
7. The Permittee shall pour spent cleaning solvent into closable containers and close
containers immediately after each use.
As required by 15A NCAC 2D .0958(d),when cleaning parts with a solvent containing a
volatile organic compound,the Permittee shall:
1. flush parts in the freeboard area,
2. take precautions to reduce the pooling of solvent on and in the parts,
3. 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,
4. not fill cleaning machines above the fill line,
5, not agitate solvent to the point of causing splashing.
Observed. No problems were observed. All paint containers were closed and there were no
spills observed. Compliance with this stipulation is indicated.
g. Condition A.8. 15A NCAC 2D .1806 "Control and Prohibition of Odorous Emissions."
Observed. No odors were observed outside the facility, and MRO has not recorded any odor
complaints concerning the facility. Compliance with this stipulation is indicated.
h. Condition A.9. 15A NCAC 2Q .0711(a)", "Emission Rates Requiring a Permit." The facility
has the potential to emit acrylamide,MEK,styrene,toluene,vinylidene chloride,xylene. The
( facility is limited to emissions levels found in the following chart:
Carcinogens _ Chronic Acute Systemic Acute
Pollutant (lb/yr) Toxicants Toxicants(lb/hr) Irritants
(lb/day) J (lb/hr)
Acrylonitrile(107-13-1) �0.22
MEK(methyl ethyl ketone,2- _ 78 22.4
butanone)(78-93-3)
Styrene(100-42-5) _ I s 2.7
Toluene(108-88-3) ���� ����� 98 _ 14.4

Cabarrus Plastics
December, 18, 2019
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V yhdene chloride(75-35-4) �� J _- 2.5
Xylene(mixed isomers)(1330-20- 57 ; 16.4
If emissions exceed these levels,modelling must be performed to determine if the
operation can continue at this level or modifications must be made to continue operations.
The facility must maintain records in such a manner that the inspector can determine if
the emission limits are being observed.
Observed. The facility no longer uses materials with MEK or vinylidene chloride. The
facility is tracking their TPER pollutant usage and emissions. The facility provided their
most recent'electronic spreadsheet tracking information,which was reviewed.I Toluene
was their largest pollutant with 77.65 lbs for the month of November,which is well
below the limit of 98 lbs/day. The emissions divided by the operating hours
demonstrates that the facility is under the TPER limits for all the listed pollutants.
Compliance with this stipulation is indicated.
8. NSPS/NESHAP review
This facility does not have generators or a fire pump and is not subject to NSPS or NESHAP.
9. Summary of changes needed to the current permit:
None.
10. Compliance assistance offered duringthe he inspection:
The facility plans to remove some of the paint booths, they were advised to keep the inspector
informed of any removals
11. Section 112(r)gpplicabilitX:
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, this facility appeared to be in compliance with the applicable air
quality regulations at the time of the inspection.
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c: MRO File
https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/CABARRUS/00156/INSPECT 20191218.docx