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HomeMy WebLinkAboutAQ_F_0400030_20190118_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Columbus McKinnon Corp-Wadesboro Operations NC Facility ID 0400030 Inspection Report County/FIPS:Anson/007 Date: 01/25/2019 Facility Data Permit Data Columbus McKinnon Corp-Wadesboro Operations Permit 03671 /Rl l 2020 Country Club Road Issued 5/14/2018 Wadesboro,NC 28170 Expires 4/30/2026 Lat: 34d 56.5990m Long: 80d 3.1730m Class/Status Small SIC: 3536/Hoists,Cranes,And Monorails Permit Status Active NAICS: 333923/Overhead Traveling Crane,Hoist,and Monorail System Current Permit Application(s)None Manufacturing Program Applicability Contact Data Facility Contact Authorized Contact Technical Contact SIP MACT Part 63: Subpart 6H Phillip Stillwell Charles Emmett Phillip Stillwell EH&S Manager General Manager EH&S Manager (704)994-6377 (704)994-6293 (704)994-6377 Compliance Data Comments: nn G!� Inspection Date 01/18/2019 / Inspector's Name Mike Thomas Inspector's ture: Operating Status Operating �•7L�J— Compliance Code Compliance-inspection Action Code FCE DnoSiggnature: On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2017 0.0100 2.12 0.0100 1409.95 2012 0.0006 --- 2.05 0.0006 1329.99 *Hi est HAP Emitted(inpounds) 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 1) DIRECTIONS: From FRO take Green Street to Gillespie and merge onto 195 BUS/301 S. Merge onto 301 S.,then take a right onto NC 71. Continue to follow signs for NC 71. Merge onto HWY 74 W. and continue for 49 miles to Wadesboro. From the intersection of HWY 74 and HWY 52 in Wadesboro,take Hwy 52 South and go 1 '/z miles to Country Club Road.Turn left and the entrance to building is about 50 yards on right hand side. Enter through front office. 2) SAFETY CONSIDERATIONS: Standard DAQ safety equipment.Be aware of forklift traffic in the warehouse, as well as the heavy hoists that are transferred via overhead conveyor systems to the paint booths. 3) FACILITY AND PROCESS DISCRIPTION: The facility produces electric and hand-operated chain and cable hoists, as well as support components for hoists. Hoists range in size from 250 pounds to 20 tons lifting capacity. Housing castings and hoist parts are received from outside vendors,and the hoists are assembled and painted at this facility. There is a small metal grinding operation for removal of any extraneous metal or burrs from the metal castings. After full assembly,the hoists are painted in one of three paint spray booths. The paint booths are equipped with integral panel filters to capture paint overspray droplets. The painting operations became subject to NESHAP Subpart 6H because the facility utilized coatings that contained Chromium in excess of 0.1%or Lead in excess of 1%by weight. Note that the facility has now discontinued the use of coatings with 6H Target HAP. However,the facility has requested that the Subpart 6H requirements be retained in the permit and has not requested an exemption from the regulation for not using the target HAP. 4) PERMITTED EMISSION SOURCES: Emission Emission Source Control Control System li Source ID Description System ID Description ES-1375 One paint spray booth with integral panel filters N/A N/A (NESHAP) Not Operating ES-SPR-9 One paint spray booth with integral panel filters N/A N/A (NESHAP) Operating with 0%V.E. ES-SPR-14 One paint spray booth with integral panel filters N/A N/A (NESHAP) Operating with 0%V.E. INSIGNIFICANT/EXEMPT ACTIVITIES: _........ ...._ .. Source Exemption Regulation Source of TAPs? Source of Title V Pollutants? IES-FP 2Q.0102(h)(5) No Yes Foam Packaging IES-MG 2Q.0102(h)(5) No Yes Metal Grinding Operation 5) INSPECTION CONFERENCE: On 17 January 2019,I Mike Thomas and Evangelyn Lowery-Jacobs,both of FRO DAQ arrived at Columbus McKinnon to conduct a compliance inspection. We met with the facility contact Phillip Stillwell, EH&S Manager. We discussed the following: a) Mr. Stillwell verified the FACFINDER;no changes were needed. b) I inquired if any of the plant's operations had change. Mr. Stillwell stated that their operations were the same and their production levels were about the same as last year. He went on to say that the facility is potentially adding another paint booth. He was not certain whether it would replace one of the existing booths or be an additional booth. Mr. Stillwell said that he would contact me once he had all of the details. He also mentioned that the facility had taken on a new product line from Germany and that often those items had to be touched up with spray paint. c) Production: Year ES-1375 ES-SPR-14 ES-SPR-9 Total Paint Total VOCs gallons gallons gallons Usage Tons gallons* 2018 1,320 2.34 2017 1,104 533 260 2.10 2016 4,400 450 975 3.08 2015 4,410 476 993 7.0 2014 4,595 494 138 7.79 *For the last permit renewal the facility grouped all of the painting sources together and are now reporting the total amount of paint used in gallons. 6) INSPECTION SUMMARY: Mr. Stillwell led us on a tour of the facility which was operating. We observed the three paint booths (ES-1375,ES-SPR-9, and ES-SPR-14). All three booths are clearly labeled,according to the permit Emission Source ID.All three of the booths appeared to be clean and well maintained.ES-SPR-9 and ES-SPR-14 were operating. Operators keep a filter log outside of each booth,noting when the filters are changed. We checked each log and all had current entries.Magnahelics on all three appeared to be functioning properly and were within the appropriate range compared to logbook readings. We observed no problems with any of the paint booths. 7) PERMIT STIPULATIONS: A. A.2 2Q .0304 PERMIT RENEWAL and EMISSIONINVENTORYREQUIREMENT— Entire facility subject. Submit permit renewal application and EI at least 90 days prior to permit expiration. Appeared to be in compliance— The facility's most recent emissions inventory and permit renewal were received on time. The next deadline for emissions inventory and permit renewal is December 2025 for the 2024 calendar year. B. A.3 2D .0515 PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES Particulate matter emissions shall not exceed allowable emission rates Appeared to be 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. C. A.4 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENT-Visible emissions from the emission sources manufactured after July 1, 1971, shall not be more than 20% opacity. Appeared to be in compliance-We observed 0%VE from the two operating sources during this inspection. D. 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. Appears to be in compliance—Mr. Stillwell stated that he was unaware of any exceedances, breakdowns, or abnormal conditions that would require notification. E. A.6 2D .0540 FUGITIVE DUST CONTROL REQUIRMENT—The Permittee shall not cause or allow fugitive dust emissions to contribute to complaints or excessive visible emissions beyond the property boundary. Appeared to be in compliance—We observed no fugitive dust emissions.This facility has all paved roads and parking. FRO DAQ has received no complaints against the facility. Mr. Stillwell stated that he has not received any dust complaints. F. A.7 2D .1111 MAXIMUMACHIEVABLE CONTROL TECHNOLOGY—Applicability of GACT Subpart'^' ^nHHHHH"Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources"—Facility must use High Volume Low Pressure(HVLP)spray heads for painting,paint booth filters must provide at least 98%capture efficiency,maintain records of training and certifications for each employee conducting paint spraying operations. Appeared to be in compliance—The facility maintains the three spray paint booths in compliance with 6H requirements including HVLP spray guns. Records are kept for each employee that operates a spray booth documenting their training history. Records are maintained documenting the filter efficiency(98%)and frequency of maintenance for each spray booth. The last training session for the paint staff was on 5 June 2018. The facility continues to adhere to the requirements of 6H even though the paints in use do not contain the subject chemicals. G. A.8 2Q .0711 TOXICAIR POLLUTANTEMISSIONLIMITATIONREQUIREMENT— The Permittee shall maintain records of operational information demonstrating that the TAP emissions do not exceed the TPER listed as M1BK 52 lbs/day,Toluene 98 lbs/day,and Xylene 57 Ibs/day. Appeared to be 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. H. A.9 2Q .0803 COATING,SOLVENT CLEANINGAND GRAPHICARTS EXCLUSIONARYRULE REQUIREMENTS-The facility potential emissions shall be less than 100 tons per year VOC, 10 tons per year each HAP, and 25 tons per year all HAPs. The Permittee shall maintain records and submit an annual report of facility emissions. Appeared to be in compliance—The facilities emissions are well below the limits set forth above. 2.1 tons of VOC, 1.03 tons of Xylene, and 1.23 tons total for HAPs. The facility's latest annual report was received on 28 February 2018 and was compliant. The facility bases compliance on worst case scenario. 8) 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). 9) NON-COMPLIANCE HISTORY SINCE 2010: None. 10) COMMENTS AND COMPLIANCE STATEMENT: Columbus McKinnon Corp.—Wadesboro Operations appeared to be in compliance with the conditions in their current air permit on 17 January 2019. /mst