AQ_F_0200098_20181205_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Piedmont Composites and Tooling,LLC
NC Facility ID 0200098
Inspection Report County/FIPS:Alexander/003
Date: 12/05/2018
Facility Data Permit Data
Piedmont Composites and Tooling, LLC Permit 09941 /T03
33 Lewittes Road Issued 4/18/2018
Taylorsville,NC 28681 Expires 3/21/2023
Lat: 35d 55.0386m Long: 81d 8.6994m Classification Title V
SIC: 3089/Plastics Products,Nec Permit Status Active
NAICS: 326121 /Unlaminated Plastics Profile Shape Manufacturing Current Permit Application(s)TV-Renewal
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
David Himebaugh David Himebaugh Paul Zawila
MACT Part 63: Subpart WWWW
President President Senior Environmental
[phone] [phone] Engineer
[phone]
Compliance Data
Comments:
Inspection Date 12/05/2018
Inspector's Name Karyn Barksdale
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: �� �8 On-Site Inspection Result Violation
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2017 0.6400 --- --- 27.81 --- 0.3200. 23459.96
2016 0.6100 --- --- 24.53 --- 0.3000 23477.92
2015 0.3700 --- --- 19.63 --- 0.1800 19899.56
* Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
03/26/2018 NOV 2D .I I I I Maximum Achievable Control 05/04/2018
Technology
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

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December 5,2018
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Type X Full Compliance —Partial Compliance _Complaint Other:
Action: Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 12/7/2018 X IBEAM 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 _IBEAM Complaint
checked X IBEAM Planning,Next Inspection Date
12/1/2019
Directions: From Statesville,take exit 148 on I-40 West and turn right. Follow Hwy. 64 North to
Adam's Pond Lane. Turn right onto Adam's Pond Lane. Turn left onto Highway 90. Facility is less than
half a mile on right(old Kincaid furniture plant with water tank).
Safety Equipment: Safety shoes and safety glasses are recommended.
Safety Issues: None noted.
Coordinates: A review of the facility's coordinates on"Maps of DAQ Regulated Facilities" indicates the
facility's latitude and longitude coordinates are accurate. Latitude and longitude coordinates of this facility
are locked in IBEAM.
Email Contacts: Facility contacts were verified; no changes were needed.
1. General Information. The purpose of this site visit was to conduct a routine air quality inspection. This
facility manufactures fiberglass church steeples, baptisteries, and a small number of specialized
fiberglass components for car dealership signs, boat parts,water slides,campers,hospital clean rooms.
In addition to production areas,the facility utilizes space for storage of either molds or finished product.
The plant operates 10 hours per day,four days of the week(Monday through Thursday)with occasional
Friday shifts. The mailing address for this facility is 33 Lewittes Road,Taylorsville,NC, 28681.
2. I arrived at the facility at approximately 9:30 AM on December 5, 2018. I first met with Mr. Doug
Caudle and then Mr. Chris Johnson accompanied me on the facility inspection.
3. File Review.
A. Contacts. Facility contacts were verified; no changes were needed.
B. Files. The following files were reviewed prior to the inspection: previous inspection reports;
correspondence since the last inspection; semiannual, and annual reports, complaints, annual
emissions inventories, etc.

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December 5, 2018
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C. Compliance history.
The facility was issued an NOV on March 26, 2018 for failure to monitor and keep records of
gallons of HAP coatings used required to avoid applicability of 15A NCAC 2D .I 111.
The facility was issued an NOD on July 24, 2013 for failure to keep records of monthly usage of
HAP coatings required to avoid applicability of 15A NCAC 2D .1111 (40 CFR 63, Subpart PPPP,
NESHAP for Surface coating of plastic Parts and Products).
The facility was issued an NOV on September 9, 2013 for construction,and operation prior to
obtaining an Air Quality Permit for the sanding operation for fiberglass wall panels with
associated bagfilter.
D. Operating Conditions established by Stack Testing.—N/A.
E. Records Required by Title V. During this inspection all records, required by the Title V permit,
were reviewed. The records appear to be in compliance, based on information submitted.
F. NSPS/NESHAP Review
The facility is subject to NESHAP Subpart WWWW — NESHAP for Reinforced Plastics
Composites Production. Compliance with this MACT is discussed below.
The facility also has an avoidance condition in the permit for NESHAP Subpart PPPP — Surface
Coating of Plastic Parts and Products. Compliance with this avoidance condition is discussed
below.
There are two inactive boilers that are abandoned in place. The boilers were used by the previous
owner of the building. There are no emergency generators at the facility. Therefore,NESHAP 4Z
and 6J do not apply.
The facility does not have any gasoline storage tanks onsite; therefore, is not subject to NESHAP
6C.
4. Part I-AIR QUALITY TITLE V OPERATION PERMIT. The following permitted emission sources
and/or control devices listed in Section 2 Paragraph 2.1- Emission Source(s) and Control Devices(s)
- Specific Limitations and Conditions were observed during this inspection:
A.
Emission Source Control Control Device
ID No. Emission Source Description Device Description
ID No.
002 Laminating/gel coat operation N/A N/A
MACT WWWW
006* Resin storage tank(5,880 gallons) N/A N/A
MACT WWWW
The laminating and gel coat operations are located in different areas of the plant. Gel coating is
typically performed early in the morning. The facility also has an area for closed molding

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Page 4
operations. Loss of styrene emissions from closed molding is approximately 1%while loss of
styrene from open molding is approximately 17%. The resin tank is located outside the building.
Observed. The gel coat area was observed in operation at the time of inspection. The
laminating area was observed in operation with no visible emissions. The resin tank was
observed at the time of inspection with no visible emissions.
1. 15A NCAC 2D .0521: Control of Visible Emissions-
Visible emissions from each source shall not be more than 20 percent opacity when averaged
over a six-minute period. No monitoring/recordkeeping/reporting is required.
Observed. No visible emissions were observed during the time of inspection. The facility is
performing monthly visible emission although not required. The most recent observation
occurred November 13, 2018. Compliance with this stipulation is indicated.
2. 15A NCAC 2D .1111: Maximum Achievable Control Technology
The Permittee shall comply with all applicable provisions contained in Environmental
Management Commission Standard 15A NCAC 2D .1111, "Maximum Achievable Control
Technology" (MACT) as promulgated in 40 CFR 63, Subpart WWWW, "National Emission
Standards for Hazardous Air Pollutants for Reinforced Plastic Composites Production,"
including Subpart A "General Provisions" as follows:
The Permittee shall limit its organic hazardous air pollutant (HAP) emissions from its open
molding, gel-coating operations(ID No. 002)as described in 63.5805(b)and Table 3 - Subpart
WWWW,which include, in part:
If your operation And you use... Your organic HAP
is... emissions limit is...
Open molding—non- Mechanical resin application 88 (lb/ton)
corrosion-resistant Filament application 188 (lb/ton)
and/or high strength Manual resin application 87 lb/ton
Open molding— Mechanical resin application 254 (lb/ton)
tooling Manual resin application 157 lb/ton
Open molding—gel Tooling gel coating 440 (lb/ton)
coat White/off white pigmented gel 267 (lb/ton)
coating 377 (lb/ton)
All other pigmented gel coating 522 (lb/ton)
Clear production gel coat
As specified in 40 CFR 63.5805(b),the Permittee must meet all applicable work practice
standards in Table 4 of MACT Subpart WWWW, including:

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December 5, 2018
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For... You must...
All cleaning operations Not use cleaning solvents that contain HAP, except
that styrene may be used as a cleaner in closed
systems, and organic HAP containing cleaners may be
used to clean cured resin from application equipment.
Application equipment includes any equipment that
directly contacts resin.
All HAP-containing materials Keep containers that store HAP-containing materials
storage operations closed or covered except during the addition or
removal of materials. Bulk HAP-containing materials
storage tanks may be vented as necessary for safety.
All mixing operations Use mixer covers with no visible gaps present in the
mixing covers, except that gaps of up to one inch are
permissible around the mixer shafts and any required
instrumentation.
Keep the mixer covers closed while actual mixing is
occurring except when adding materials or changing
covers to the mixing vessels.
The Permittee shall demonstrate that, on average,the individual organic HAP emission limits
for each unique combination of operation type and resin application method or gel coat type
are met. If all emission factors are equal to or less than their corresponding emission limits,
then the Permittee is in compliance. The results of the monitoring shall be maintained in a
logbook on-site and made available to an authorized representative upon request. Summary
reports are required to be submitted semi-annually.
Observed.The facility contracts with Value Environmental to maintain monthly emission logs
for compliance with this MACT. As shown in the below table, the facility demonstrates
compliance with this MACT on a monthly basis by determining a styrene weighted average for
all resins/gelcoats used (based on the emission factors listed in the table above) and then
determines the average styrene emissions based on materials purchased. To comply with the
requirement that prohibits the use of HAP containing solvents, the facility uses acetone as a
cleaning solvent.
The monthly logs were observed from March 2018 through July 2018; records for August
2018 through November 2018 were not readily available onsite and were requested via email.
Semi-annual reports were received on July 26, 2018 and January 30, 2018 as required.
During inspection,the mixers (55-gallon drums)were observed to have covers and they were
in place. The mixer mechanism was attached to the lid. The facility also does some mixing
in 5-gallon buckets. These buckets were observed to have lids properly closed. A portable
mixer is used for the buckets. Compliance with this stipulation is not indicated since the
monthly calculations were not conducted.
Month Allowable Styrene Weighted Styrene
Content Average
(lb/ton) lb/ton
Mar 2018 152.2 129.3

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Month Allowable Styrene Weighted Styrene
Content Average
lb/ton lb/ton
Apr 2018 146.0 123.7
May 2018 148.3 126.0
June 2018 143.1 120.6
July 2018 142.6 120.2
Aug2018 Calculations not conducted Calculations not conducted
Sept 2018 Calculations not conducted Calculations not conducted
Oct 2018 Calculations not conducted Calculations not conducted
Nov 2018 Calculations not conducted Calculations not conducted
B.
Emission Control
Source Emission Source Description Device Control Device
ID No. ID No. Description
004 Dry filter-type surface coating N/A N/A
operation
Observed. The paint booth was observed in operation at the time of inspection. The dry filters
appeared to be well maintained and in proper place.
1. 15A NCAC 2D .0515: Particulates from Miscellaneous Industrial Processes
Emissions of particulate matter from this source (ID No. 004) shall not exceed an allowable
emission rates. The facility is required to perform monthly visual inspections of the dry filter,
and an annual (for each 12-month period following the initial inspection) inspection of the
associated ductwork noting the structural integrity.
The results of inspection and maintenance shall be maintained in a log. The log shall record
the following: the date and time of each recorded action; the results of each inspection; the
results of any maintenance performed on the dry filter, and any variance from manufacturer's
recommendations, if any, and corrections made. No reporting is required.
Observed. Records of the monthly visual inspections of the. dry filter were observed from
April 2018 through November 2018. Filter issues were corrected during the September 13,
2018 inspection. The inspection sheets indicated they do inspect the structural integrity of the
ductwork on a monthly basis even though this is required annually. Compliance with this
stipulation is indicated.
2. 15A NCAC 2D .0521: Control of Visible Emissions
Visible emissions shall not be more than 20 percent opacity when averaged over a six-minute
period. To assure compliance, once a month the Permittee shall observe the emission point(s)
of this source(ID No. 004)for any visible emissions above normal. The monthly observation
must be made for each month of the calendar year period to ensure compliance with this
requirement.

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December 5, 2018
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The results of inspection and maintenance shall be maintained in a log. Summary reports are
required to be submitted-semi-annually.
Observed. Monthly visible emission observations were performed,and records were reviewed
from April 2018 through November 2018. The most recent observation occurred November
13, 2018. These records indicated no deviations occurred. Semi-annual reports were received
on July 26, 2018 and January 30, 2018 as required. Compliance with this stipulation is
indicated.
3. NESHAP Avoidance Condition for Surface Coating of Plastic Parts and Products (40
CFR 63, Subpart PPPP)
In order to avoid applicability of this rule, the facility is limited to using less than 100 gallon
of HAP coatings per consecutive 12-month period to coat plastic parts or products.
The facility is required to keep records of gallons of HAP coatings that are used to coat plastic
parts or products on a monthly basis. Summary reports are required to be submitted semi-
annually.
Observed. The monthly logs were observed from March 2018 through July 2018; records for
August 2018 through November 2018 were not readily available onsite and were requested via
email. The table below shows the monthly usage and 12-month totals for HAP containing
coatings. The coatings are mostly used for water slides. Semi-annual reports were received on
July 26, 2018 and January 30, 2018 as required. Compliance with this stipulation is not
indicated since records were not kept.
Month Monthly Usage 12-Month Total
(gals) (gals)
Mar 2018 3.6 10
Apr 2018 0 10
May 2018 0 10
June 2018 0 10
July 2018 0 10
Aug2018 no records no records
Sept 2018 no records no records
Oct 2018 no records no records
Nov 2018 no records no records
C.
Emission Source Control Control Device
ID No. Emission Source Description Device Description
ID No.
005* Sanding Operations DC001 Dust Collector
(800 square feet
of filter area)
Observed. The sanding operation was in operation at the time of inspection. This is mostly used
for sanding edges of boards used for hospital clean rooms.

Piedmont Composites and Tooling, LLC
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1. 15A NCAC 2D .0515: Particulates from Miscellaneous Industrial Processes
Emissions of particulate matter from this source (ID No. 005) shall not exceed an allowable
emission rates. The facility is required to perform monthly visual inspections of the filters,
system ductwork,and material collection unit.An internal(for each 12-month period following
the initial inspection)inspection is required for the dust collector.The results of inspection and
maintenance shall be maintained in a log. No reporting is required.
Observed. Monthly visual inspections are being conducted and recorded. Records of the
monthly visual inspections of the filter and ductwork were observed from April 2018 through
November 2018. The annual inspection was done on January 18, 2018 and the previous one
was done on January 12, 2017. Compliance with this stipulation is indicated.
2. 15A NCAC 2D .0521: Control of Visible Emissions
Visible emissions shall not be more than 20 percent opacity when averaged over a six-minute
period. To assure compliance, once a month the Permittee shall observe the emission point(s)
of this source(ID No. 005)for any visible emissions above normal. The monthly observation
must be made for each month of the calendar year period to ensure compliance with this
requirement. The results of monitoring shall be maintained in a log. Summary reports are
required to be submitted semi-annually.
Observed. Monthly visible emission observations were performed, and records were
reviewed from April 2018 through November 2018. The most recent observation occurred
November 13, 2018. These records indicated no deviations occurred. Compliance with this
stipulation is indicated.
5. Part I-AIR QUALITY TITLE V OPERATION PERMIT. The following permitted emission sources
and/or control devices listed in Section 2 Paragraph 2.2- Multiple Emission Source(s) Specific
Limitations and Conditions were observed during this inspection:
A. Facility-Wide
1.. Toxic Air Pollutant Emission Limitations and Reporting Requirements
In accordance with the approved application, the Permittee shall maintain records of
operational information demonstrating that the TAP emissions do not exceed the TPERs for
ethyl acetate,methyl ethyl ketone, methyl isobutyl ketone, n-hexane,toluene, and xylene.

Piedmont Composites and Tooling, LLC
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TPERs Limitations
Pollutant(CAS Number) Carcinogens Chronic Toxicants Acute Systemic Acute
(Ibiyr) GbIday) Toxicants(1h.1hr) Irritants
A (Ibiltr)
cihV18uclate
(141-78-6)
methyl cthyl ltctoa-c 78 22.4
(78-93-3) t
methyl isobutyl ketone 52 7.6
. (1os-ta-1 j
n-hexane 23
Toluene 98 14.4
(1D8-88-3)
(1330-20-7)
Observed. The facility maintains records of the TAPS that are also categorized as HAPs (not
ethyl acetate and MEK)through the monthly recordkeeping requirements for MACT Subpart
WWWW and for avoidance to MACT Subpart PPPP. The ethyl acetate and MEK are tracked
and reported in the EI. Compliance with the TPER limits were verified in the review of the
2017 emissions inventory. Compliance with this stipulation is indicated.
4. 15A NCAC 2D .1100: Control of Toxic Air Pollutant Emissions
Pursuant to 15A NCAC 2D .1100 and in accordance with the approved application for an air
toxic compliance demonstration,the following permit limits shall not be exceeded:
Pollutant Emission Source(s) Allowable Emission
Rate
styrene facility-wide 39.21b/hr
The facility is required to maintain a logbook that records the facility-wide hourly styrene
emissions. The hourly rate is determined and recorded on a monthly basis. The facility is also
required to report semi-annually the single highest facility-wide hourly emission rate for
styrene for the previous six months
Observed. Facility-wide hourly styrene emission rates are determined from the monthly logs
required for MACT Subpart WWWW. Once the monthly records are compiled, the facility
divides the monthly styrene emissions by the number of hours worked during the month. Semi-
annual reports were received on July 26, 2018 and January 30, 2018 as required. The report
received July 26, 2018 indicated that the highest facility-wide hourly emission rate for styrene
was 15.81 pounds per hour(1st half of 2018). Compliance with this stipulation is indicated.
5. 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.

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December 5, 2018
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Observed. No odors were detected outside the property boundaries. Compliance with this
stipulation is indicated.
6. Part I -AIR QUALITY TITLE V OPERATION PERMIT. Section 3 - GENERAL CONDITIONS
A. Permit. Maintain a copy of the permit and application at the facility. Observed. The permit and
application are at the facility.
B. Submissions. Except as otherwise specified, two copies of all documents, reports, test data,
monitoring data are required to be submitted to MRO. Observed. The company has been
complying with this requirement.
C. Circumvention. Operate and maintain the facility at all times in a manner that will affect an overall
reduction in air pollution. Observed. The company has been complying with this requirement.
D. Excess Emissions. Report excess emissions and permit deviations as required. Observed. No
excess emissions have occurred to date.
E. Retention of Records. The Permittee shall retain records of all required monitoring data and
supporting information for a period of at least five years from the date of the monitoring sample,
measurement, report, or application. Observed. Records are being retained.
F. Compliance Certification. By March I", submit a compliance certification (for the preceding
calendar year). Observed. The ACC was received on February 1,2018.
G. Emissions Inventory. Submit an emissions inventory by June 30 of each year. Observed. The
facility has been complying with this requirement. The most recent EI for calendar year 2017 was
received June 25, 2018.
H. Refrigerant Requirements (Stratospheric Ozone and Climate Protection). Dispose of refrigerants
properly. Observed. The facility complies with this requirement by using a certified outside
contractor.
I. Section 112(r). This facility appears does not appear to be subject to the requirements of the
Chemical Accident Release Prevention Program, Section 112(r)of the Clean Air Act.
7. The following non-permitted air emission sources and control devices were observed as follows:
A. Grinding Area(ID No. IES-01)
Observed. The grinding area, also identified as the trim room, is located in a separate room.
Particulate emissions are collected by an air filtration system that vents back into the room. This
was observed operating at the time of inspection.
B. Woodworking Operations(ID,No. IES-02)
Observed. This was observed in operation at the time of inspection. This is used to make molds
for casting. Particulate emissions are collected by an air filtration system that vents back into the
room.

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C. Welding Operations (ID No. IES-03)
Observed. No welding was being done at the time of inspection. The welding operations is
located inside the facility.
D. Solvent cleaning operation(ID No. IES-04)
Observed. The facility uses acetone as a cleaning solvent. The facility has a reclamation unit for
recycling acetone.
E. natural gas-fired make-up heaters(ID No. IES-08)
Observed. These heaters were not observed at the time of inspection.
8. Other compliance requirements and issues:
None.
9. Compliance Assistance.
None.
10. Findings.
Based on my observations during this inspection, this facility appeared to be in non-compliance with
the monitoring requirements for NESHAP Subpart WWWW and Subpart PPPP, specific permit
conditions no. 2.1.A.2.d.i and 2.1.B.3.b, respectively. An NOV was issued to the facility on March
26,2018 for the same violation. Therefore,this occurrence will result in the issuance of an NOV/NRE.
KRB:lhe
c: MRO File
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