AQ_F_1300029_20191001_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: 10/0 1/2019
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 Plant Manager
[phone] (704)455-5 102 [phone]
—T Compliance Data
Comments:
Inspection Date 10/01/2019
Inspector's Name Karyn Kurek
Inspector's Signature: Operating Status Operating
�-- Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: w�21 l 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 inRounds)
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.
October 1,2019
Page 2 of 8
-----------------
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review: 10/09/2019 J 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 I)ate
10/01/2021
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/Lona Coordinates: The"Maps of DAQ Regulated Facilities" is unavailable,however a review of the
facility's coordinates on "Maps of DAQ Regulated Facilities"last inspection indicated the facility's latitude
and longitude coordinates were accurate and locked within IBEAM.
Email contacts:The facility contacts were reviewed.Mr. Laurens Willard was added as the Technical
Contact in the event that Mr. Londhe was unavailable to the Inspector.
1. Inspection:
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 Tuesday, October
1, 2019 at approximately 9:16 AM. Mr. Harshad Londhe, Plant Manager, and Mr. Laurens Willard, Plant
Manager(in-training),accompanied me on the inspection. Since the facility has had several complaints in the
past and a recent inquiry from the media,they will remain on an annual inspection cycle for the time being.,
2. Facility Contact Information:
The facility contacts were reviewed. Mr.Laurens Willard was added as the Technical Contact in the event
that Mr. Londhe was unavailable to the Inspector.

Galvan Industries Inc.
October 1, 2019
Page 3 of 8
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 bagfilter 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 bagfilter and, as a result, were vented through roof top
fans. To increase the capture efficiency of the bagfilter,the roof top fans on the galvanizing building
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 ` 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

Galvan Industries Inc.
October 1,2019
Page 4 of 8
----.——__...---- —---- _. __................ _--- -...—_.....__..........._.._... ------._.._...................... ... ......
Emission Emission Source Control Control System
Source ID Description System ID ! Description
... . __._ .. ..
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.
i
Observed:The kettle(ID No. GK-I)and bagfilter(ID No.BH-2)were observed in operation at the j
time of inspection with no visible emissions.
shot blasting machine bagfilter(3,500 square
SBM-1 (14,350 pounds per hour BH-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 ini
-operation at the time of the inspection with no visible emissions.
5. Observations of insignificant air emission sources and control devices listed on the current permit:
F � — Source Observed
........................... .. _.... -- -.
1IEX-1 -sodium hydroxide(NaOH)tank This storage tank was observed at the
(8,500-gallon capacity) time of inspection with no issues noted.I
IEX-2-sulfuric acid tank This storage tank was observed at the
i
(14,100-gallon capacity) time of inspection with no issues noted.
t
X-5 -zinc chloride/ammonium chloride pre- This storage tank was observed at the
x tank(8,400-gallon capacity) time of inspection with no issues noted.
r(1IE3�-6 -water rinse tank This storage tank was observed at the
4,100-gallon capacity) time of inspection with no issues noted.
_ .......
IEX-7 -water rinse tank This storage tank was observed at the
(9,700-gallon capacity) time of inspection with no issues noted.
—._..:. -.._...... -- --—_...__.................---�_-.. ----------...-
JIEX-8
-water quench tank This storage tank was observed at the
(I8,000-gallon capacity) time of inspection with no issues noted.
IEX-9-natural gas/propane-fired boilerThis unit was not observed at the time
.(8.4 million Btu per hour maximum heat input) of inspection.
�IEX-3 -sulfuric acid tank This storage tank was observed at the
(14,100-gallon capacity) time of inspection with no issues noted.
IEX-4 -sulfuric acid tank This stora an ge ta was observed at the
(14,100-gallon capacity) time of inspection with no issues noted.
. ..... -- ._... _... _ .. . ....
IEX-11 -sulfuric acid tank This storage tank was observed at the
(5,000-gallon capacity) time of inspection with no issues noted.

Galvan Industries Inc.
October 1, 2019
Page 5 of 8
I EX-12 -propane storage tank This storage tank was observed at the
!(I 8,000-gallon capacity) [time of inspection with no issues noted.
!I EX-13 -process water tank This storage tank was observed at the
(I 6,000-gallon capacity) time of inspection with no issues noted.
.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 and is being inspected on
,(8.7 square feet of filter area; 40 gallons per an annual basis. The facility is keeping
minute minimum liquid injection rate) installed records of the inspections.
on a copper electroplating process
'I EX-15 -sodium hydroxide(NaOH)tank This storage tank was observed at the
(2-gallon capacity) time of inspection with no issues noted.
6. Observations of air emission sources and control devices not listed on the current permit:
None.
7. Compliance with specific permit conditions and limitations:
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 03639RI5 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 Nov.
27, 2018 and July 16, 2019 (previous inspection resurfacing dates were November 9, 2016, April
29, 2017, October 28, 2017 and May 1, 2018). The resurfacing typically occurs every 6 months.
Compliance with this stipulation is indicated.
C. Condition A. 4. "Particulate Control Requirement" as required by 15A NCAC 213 .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.

Galvan Industries Inc.
October 1,2019
Page 6 of 8
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.
F. Specific Condition and Limitation No.A. 7. "Notification Requirement" as required by NCAC2D
.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. At the time of inspection,
the facility grounds were treated and wet. 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 fi•om 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);

Galvan Industries Inc.
October 1,2019
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- 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. 131-1-1). The shot blaster and associated bagfilter
were observed in operation at the time of inspection with no issues noted. 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
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 log book of maintenance and inspections for bagfilters BH-1 and BH-2 was
maintained and available at the time of inspection(see table below). The facility pays to have the
vendor of the kettle bagfilter come onsite to ensure continued proper operations as noted below;
this practice is above and beyond the permit requirement. The shot blasting bagfilter is due for
inspection this month(October 2019)and the facility understands this requirement and will ensure
the inspection is completed as required. Compliance with this stipulation is indicated.
Emission Source Most Reeent Ius ection s
Kettle(131-1-2) 10/20/2018-vendor onsite
11/2/2018
11/11/2018
5/3/2019-vendor onsite
5/8/2019
6/5/2019
6/13/2019
6/24/2019
Shot Blasting(BH-1) 4/17/2018
7/2/2018
10/27/2018

Galvan Industries Inc.
October 1,2019
Page 8 of 8
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 froth 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 during the 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.
The facility does not have any generators therefore it is not subject to NES14AP 4Z.
The facility does not have any boilers therefore it is not subject to NESHAP 6J.
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,this facility appeared to be in compliance with the applicable air quality
regulations at the time of the inspection.
KRB:Ihe
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