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. If removed,this would also remove the annual report requirement.
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