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HomeMy WebLinkAboutAQ_F_0900049_20181204_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Taylor Mfg NC Facility ID 0900049 Inspection Report County/FIPS: Bladen/017 Date: 12/10/2018 Facility Data Permit Data Taylor Mfg Permit 06963/R05 1585 US 701 South Issued 3/14/2016 Elizabethtown,NC 28337 Expires 2/29/2024 Lat: 34d 36.7370m Long: 78d 36.8200m Classification Small SIC: 3559/Special Industry Machinery Nec Permit Status Active NAILS: 333111 /Farm Machinery and Equipment Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Charles King Denise Bridgers Denise Bridgers Plant Supervisor Secretary Treasurer Secretary Treasurer (910)862-2576 (910)862-2576 (910)862-2576 Compliance Data Comments: Inspection Date 12/04/2018 vv �� Inspector's Name Mike Thomas 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 2014 --- --- --- 16.47 --- --- 2728.11 2009 --- --- --- 6.17 --- --- 905.00 *Highest HAP Emitted(in ounds) Five Year Violation History:None Date Letter TYDe 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: ------ - Emission Emission Source Control Control Source ID Description System ID System Description Paint spray booth with integral panel filters ES 1 96 square feet of filter area N/A 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 A ES4 156 square feet of filter area N/A N/A Not Operating; F F Paint spray booth with integral panel filters A ESS 156 square feet of filter area N/A N/A Not Operating; Paint spray booth with integral panel filters � A ES6F 156 square Feet of filter area N/A N/A Not Operating; 5. INSPECTION CONFERENCE: On 4 December 2018, I Mike Thomas and Evangelyn Lowery-Jacobs,both of FRO DAQ conducted a compliance inspection of the Taylor Manufacturing facility. We 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 for the 2017 calendar year and Ms. Bridgers stated that production has decreased significantly and that painting has become a seasonal activity at the facility. c THROUGHPUTS: Year VOC,TPY Total HAPs, Largest HAPs, HAP type TPY TPY 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: Ms.Bridgers led us down to the building where all of the paint booths are housed. Each paint booth is very large and at first appearances did not seem well maintained. I inquired about the frequency of filter changes. The facility's painter, stated that he 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 2D.0202—"Permit Renewal and Emission Inventory Requirement"—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 REOUHREMENT— 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.4 213.0521 VISHiLE 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. We 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 stated there have been no occurrences of excessive 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-We 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. A.7 2D .0958(c)WORK PRACTICES REQUIREMENTS—Careful handling, storage and clean-up of solvents. APPEARED IN COMPLIANCE—The facility appears to be continuing with good work practices regarding storage and clean-up of VOC containing materials, even though this permit condition no longer applies. A.8 20.0711 TOXIC AIR POLLUTANT EMISSIONS LINMATION REQUIREMENT- The Permittee shall limit the emissions of all TAPS, including styrene,toluene,MEK, and xylene to less than the TPER limit. 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 2017 was received 27 March 2018 and reported: Total VOCs—2.6 Tpy; Greatest HAPs(toluene)—0.23 Tpy; and Total HAPs— 0.27 Tpy. 8. NON-COMPLIANCE HISTORY SINCE 2010: 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/RECOMIENDATIONS: Taylor Manufacturing appeared to be in compliance with the conditions in the facility's current air permit on 4 December 2018. Pink Sheet: Recommend removing the 2D .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. 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