AQ_F_0000074_20190306_CMPL_InspRpt (4)

0000074 - Al (�
NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Altec Industries,Inc.-Burnsville Facility
NC Facility ID 0000074
Inspection Report County/FIPS: Yancey/199
Date: 03/22/2019
Facility Data Permit Data
Altec Industries,Inc. -Burnsville Facility Permit 09587/R03
150 Altec Drive Issued 12/16/2015
Burnsville,NC 28714 Expires 11/30/2023
Lat: 35d 54.8198m Long: 82d 21.5802m Class/Status Synthetic Minor
SIC: 3713 /Truck And Bus Bodies Permit Status Active
NAICS: 336211 /Motor Vehicle Body Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Robin Sirkin Jeff Mooney Bruce Stainbrook
Safety and Environmental General Manager Corporate Environmental
Coordinator [phone] Manager
[phone] [phone]
Compliance Data
Comments:
Inspection Date 03/06/2019
Inspector's Name Amro Ali
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: /� Z (/ On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2014 0.4700 0.0100 1.83 48.32 1.54 0.4700 1879.58
2009 1.96 --- 1.50 12.35 1.30 1.96 207.00
* Highest HAP Emitted(in pounds)
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
DIRECTIONS: From Asheville,proceed east on I-26 to Hwy 19E. Proceed past Prices Creek and take the next left on to Old 19E.
The facility is about 0.1 of a mile from that intersection on the right.
Process Description
Steel components are stamped and cut to size for utility truck cabinets. Steel panels are shaped if necessary and
staged for fabricated. Once the units are welded together,they may be conveyed to one or more of the following;
the dip-coating process line,the top-coat spray booth,the undercoating spray booth,the caulk booth and/or the
touchup and rework spray booth. Some of the truck body are attached to stock truck bodies at the Burnsville
facility,but most are staged for loading on flatbed truck trailers and are sent to the Altec facility in Creedmoor,
North Carolina to be joined to truck bodies.

Altec Industries,Inc.
Burnsville Plant
Page 2 of 5
Inspection Observations
On March 6,2019,I conducted an unannounced air quality inspection of operations at Altec Industries,Inc. in
Burnsville,North Carolina. Entry to the facility and access to records was unobstructed. I was accompanied by Ms.
Robin Sirkin, Safety and Environmental Coordinator at the time of the inspection.
During the compliance inspection I discovered an onsite a diesel fired emergency generator that is used for backup
lights for the facility and a backup for paint agitators. This emergency generator was not discussed in previous
permit reviews. The emergency generator is 200 kW Olympian. It is equipped with an hour meter and had 96 hours
of total run tune. The facility runs the generator for approximately 30 minutes for maintenance purposes.
According to the facility,the generator was installed on site in 2006.This generator is subject to 40 CFR 63, Subpart
ZZZZ. It is,however, exempt from permitting because according to the memo dated January 24,2007,because the
potential hours of operation is 500 hours for emergency generators. Therefore,this emergency generator is exempt
from permitting because of potential emissions less than 5 tons per years. The facility,however,has to perform all
the requirements set in Subpart ZZZZ. The facility is performing the maintenance requirements on the engine. The
last maintenance on the engine was performed in September 22,2018,and the requirements set in Subpart ZZZZ
were met which includes filter and oil change. This engine will need to be discussed during the next permit
modification or review.
The facility has added a significant amount of process area to the back of the production floor and expects to do an
additional expansion in the near future. While this allows for increased production,it should not affect their ability
to comply with synthetic minor emission limits. During 2017 Altec also began using zirconium in the dip coating
operation instead of the phosphate. This is not expected to impact air emission rates. The following table document
observations of specific equipment:
Description ID No. Observations
dip coating process line, ES-DCOI Observed in operation with no visible emissions; see details
consisting of approx. 12 dip on dip coating operation below.
tanks and associated holding and
mixing vessels`E-coat"
natural gas-fired dip coating ES-DO01 Overhead curing oven-Observed in operation with no
curing oven(4.5 MMBtu/hr) visible emissions
four filter-type paint spray ES-PBO1 Observed in operation with no visible emissions (Top Coat
booths 1;used to touch-up assembled truck parts after E-Coat)
ES-PB02 Observed in operation with no visible emissions(used to
apply undercoating)
ES-PB03
Observed in operation with no visible emissions(Top Coat
2;used to apply custom colors, clear coat and hardeners)
ES-PB04
Observed in operation(used as a final touch up booth)
natural gas-fired paint booth ES-POO1 Equipment observed in operation with no visible emissions
curing oven(4.5 MMBtu/hr) at the time of the inspection.
caulk booth ES-CBI All seams are caulked after the E-Coat process. We
observed that this process was in operation at the time of
the inspection.
Each stage of the dip coating operation(ES-DCO1) is labeled with the description in the following table. Note that
Stage 6 was converted from zinc phosphate to zirconium surface treatment at the end of 2016.
Stage Description
1 alkaline cleaner—Chemkleen 163—heated to 130-150°F. 22,345 gallon tank.
2 water rinse
3 water rinse(tank could be changed to acid cleaner in the future
4 water rinse

Altec Industries, Inc.
Burnsville Plant
Page`3 of 5
Stage Description
5 rinse conditioner—RC GL—titanium based surface conditioner
6 zirconium surface treatment covers iron surface with a layer
of zirconium oxide
7 water rinse
8 non-chrome sealer—Chemseal 100—organic passivating rinse
9 RO Rinse—reverse osmosis water
10 E-Coat—Powercron 600CX—heavy metal free, cationic epoxy paint
solids 14-16%; 85-100°F(primer coat)
11 post rinse—"Permeate"—removes excess paint solids which are then
transferred back to the E-Coat tank
12 post rinse—"Permeate"—removes excess paint solids which are then
transferred back to the E-Coat tank
After the final rinse,parts are lifted into the dip coating curing oven(ID No. ES-DO01)above the dip tanks. It takes
approximately 2.5 -3 hours for each part to go through the dip coating operation and the paint booth curing oven.
Exempt Sources
9.5 MMBtu/hr natural gas-fired IES-BLR Observed in operation. Boiler heats Tanks 1 and 6 on the
boiler dip coating operation(tank 1 -alkaline cleaner tank and
tank 6 -acid—zinc hos hate tank).
Electrostatic powder coating IES-PC Equipment observed not in operation. This equipment has
booth and associated natural gas- never been used and there are no plans to use the powder
fired curing oven. coating equipment.
(3.0 MMBtu/hr)
shot blast booth,controlled by IES-SB Never installed and there are no plans to install at present.
fabric filter and vented indoors
plasma cutting operations, IES-PL Observed in operation with no visible emissions.This
controlled by fabric filter and operation vents inside building.
vented indoors
welding operations IES-WELD Observed in operation with no visible emissions leaving the
building.This operation is not subject to regulation under
40 CFR 63, Subpart XXXXX because the facility's
SIC/NAICS codes are not among those targeted by the rule.
Rule Review
2D .0515 -Particulate Emissions from Miscellaneous Industrial Processes-Emissions of particulate from any stack,
vent,or outlet of any industrial process for which no other emission control standards are applicable shall not exceed
the amounts calculated by the following equation:
E=4.1OxP067
where,
E=allowable emission limit in pounds per hour
P=process weight rate in tons per hour
According to the initial permit application,the maximum process weight rate through the paint spray booth will vary
depending on what parts are being coated. However,to be conservative,a process weight rate of 500 pounds per
hour is assumed. Using the above equation,this relatively low process rate leads to an allowable emission rate of
1.62 lbs/hr. Based on information contained in the initial permit application,the calculated maximum hourly PM
emission rate from the spray booths is 1.07 lbs/hr. The latest annual report states that the 12-month rolling total for
the period ending December 2017 was 0.69 tons of particulate emissions. Assuming the facility operates 4800 hours
per year(based on the 2014 Emissions Inventory),the result is about 0.2875 lb/hr. Compliance with 2D .0516 is
indicated.
2D .0516-Sulfur Dioxide Emissions from Combustion Sources-This regulation limits SO2 emissions from
combustion sources to 2.3 pounds per million Btu. Sulfur dioxide emissions from natural gas combustion are 0.6 lb

Altec Industries, Inc. a
Burnsville Plant
Page 4 of 5
sulfur dioxide per million standard cubic foot(ref.AP-42 Table 1.4-2). The sulfur dioxide emission rate calculates
as:
(0.6 lb S02/ 1,000,000 scf) * (1 scf/1020 Btu) * 1,000,000 Btu/1 mmBm=0.000588 lb/mmBtu
Compliance with 2D .0516 is indicated while combusting natural gas. We verified that all combustions sources
were firing natural gas at the time of this inspection.
2D .0521 -Control of Visible Emissions-In order to comply with 2D.0521,the visible emissions from the facility
shall not be more than 40 percent opacity when averaged over a six-minute period except that six-minute periods
averaging not more than 90 percent opacity may occur not more than once in any hour nor more than four times in
any 24-hour period for sources manufactured as of July 1, 1971. For sources at the facility manufactured after July
1, 1971,visible emissions shall not be more than 20 percent opacity when averaged over a six-minute period except
that six-minute periods averaging not more than 87 percent opacity may occur not more than once in any hour nor
more than four times in any 24-hour period. At the time of the inspection,no visible emissions were observed from
any of the operating emission sources. Compliance with 2D .0521 is indicated.
2D .0535 -Excess Emissions Reporting and Malfunctions-This regulation requires timely reporting and
appropriate actions during periods of excess emissions and malfunctions. No such reporting has been received and I
found no evidence that the facility has released excessive emissions due to abnormal conditions such as malfunction.
2D .0540-Particulates from Fugitive Dust Emission Sources-This regulation was amended effective August 1,
2007. The regulation formerly addressed only certain types of processes. The amended regulation addresses all
facilities with activities such as:unloading and loading areas,process areas, stockpiles,stockpile working,plant
parking lots, and plant roads(including access roads and haul roads). The regulation requires a fugitive process dust
plan and abatement measures if substantive complaints are verified. I have not observed any evidence of fugitive
emissions at this facility and there have been no complaints of such. Compliance with Rule 2D .0540 is indicated.
2D .1806 -Control and Prohibition of Odorous Emissions-This regulation requires the owner or operator of a
facility to not operate without implementing 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. There have been no odor complaints with regards to this facility and we did not observe
objectionable odors at any point during the inspection. Continued compliance with Rule 2D .1806 is indicated.
20.0315 -Synthetic Minor Facilities-This regulation allows facilities with potential emissions above major source
thresholds to take voluntary, federally enforceable emission limitations to reduce their potential-to-emit and
preclude Title V applicability. Although this facility would typically be classified as prohibitory small,Altec
specifically requested synthetic minor classification instead. The facility tracks actual usage of each material
containing VOC and HAP, and calculates monthly VOC and HAP emissions by mass balance. The latest annual
report received from the Permittee covers 2018 and indicates that total annual emissions are as follows: 56.83 tons
VOC and 1.38 tons total HAP. Compliance with the synthetic minor emission limits and reporting requirements is
indicated.
20.0711 -Emission Rates Requiring a Permit-The annual report of emissions for 2018 states that TAP emission
rates are well under their respective Toxic Pollutant Emission Rates(TPERs)as shown below. TAP emission rates
are expected to remain below applicable limits, and continued compliance with 2Q .0711 is expected.
2D .1111 -Maximum Achievable Control Technologv-Maximum Achievable Control Technology(MACT)as
promulgated in 40 CFR 63, Subpart XXXXXX, National Emission Standards for Hazardous Air Pollutants Area
Source Standards (NESHAPs)for Nine Metal Fabrication and Finishing Source Categories", for Machining
(§63.11516(b))and Welding(§63.11516(t))processes-Initially,it was interpreted that Altec Industries was subject
to regulation under 40 CFR 63, Subpart XXXXXX which applies to Metal Fabrication and Finishing Sources.
Specifically,the rule applies to facilities that are primarily engaged in metal fabrication and finishing. Operating
standards are required for machining operations that use materials containing metal fabrication and finishing
Hazardous Air Pollutants(MFHAP).
The rule is triggered if the MFHAP contains cadmium,chromium,lead, or nickel in amounts greater than or equal to
0.1 percent by weight,or contains manganese in an amount greater than or equal to 1.0 percent by weight. The
triggering quantity for welding operations is 2,000 pounds per year of welding wire. The Permittee indicated that

�Altec Industries,Inc.
Burnsville Plant
Page°5 of 5
well over 2,000 pounds per year of welding wire was used and that the actual manganese content of the electrode
wive was typically between 0.9 and 1.4 percent.
However, it was later determined that neither the facility's Standard Industrial Classification(SIC)code,nor the
North American Industrial Classification System(NAICS)code are not identified in the list of SIC/NAICS code
combination included in Table 1 of the Federal Register(FR)publication of the final rule. Therefore,the facility is
not subject to the rule. Starting with Air Permit No.09587R02,welding operations are listed as insignificant source
with ID No. IES-WELD.
Compliance History
There have been no air quality compliance issues documented at this facility during the past five years.
Conclusion and Comments
At the time of the inspection,Altec Industries' Burnsville facility appeared to be operating in compliance with Air
Quality Permit 09587R03. The emergency generator should be discussed in the next permit review or modification.
In addition,future inspectors should ensure that the facility is complying with Subpart ZZZZ requirements.
I
i
i
i
I