1030215 75843
FACILITY:
ADDRESS:
Seminole Machine and Welding
PERMIT ID:
9380 Ulmerton Road
DISTRICT:
Southwest
CONTACT PHONE:
Largo, FL
ARM S NO :
727-586-0599
Expiration Date:
4/18/13
Renewal Date: 2/17/13
Test Due Date: NA
PERMIT NO:
1030215-003-AF
1030215 001
176
EMISSION UNIT DESCRIPTION: The RACT spray painting area is outside in the NW corner. An airless sprayer is
used to apply low solvent paints. Sprayer painting wand is placed in a sealed bath, which may contain solvents
such as mineral spirits, kerosene, etc., when not in use
INSPECTION DATE:
16 August 2011
INSPECTION TYPE:
 Initial

ARMS INSPECTION TYPE:
INS1
 INS2
Re-inspection
INS3
COMPLIANCE STATUS:
FUI
Complaint
 IN
Drive-by
M
N
C
SNC
Quarterly
A. General Review:
1. Permit File Review
Comments: There were no additions, amendments or modifications to the permit. There were no
issues pending.
2. Introduction and Entry
Comments: Dian Miller provided the records and the facility tour.
3. Is the Responsible Official/Authorized Representative still: Dian Miller?
Comments:
The Responsible Official/Authorized Representative’s e-mail is:
4. Is the facility contact still: Dian Miller?
Comments:
The facility contact’s e-mail is:
I
N
MNC
S
N
C
Yes
No
Yes
No
Yes
No
Yes
No
B. Specific Conditions:
This permit or a copy thereof shall be kept at the work site of the permitted activity.
[62-4.160 F.A.C. - General Condition 12.]

Comments: The facility
did have a copy of the permit on-site.
4. Emission Limitation: Total Volatile Organic Compound (VOC) emissions from this spray painting
operation (including surface preparation, painting, and equipment clean-up) shall not exceed 9.5 tons per
any consecutive 12-month period. Since all the HAPs used at this facility in a reasonable and practical
manner are expected to be VOCs, this limitation is also considered to synthetically limit HAP emissions
below the Title V permitting thresholds in Chapter 62-213, F.A.C.
{Permitting Notes: This limitation is stricter than the maximum allowable VOC limitation of 17.24
tons/year in construction permit AC52-195852.}
[Construction Permit AC52-195852; Rule 62-210.300(2)(b), F.A.C.; As requested by Ms. Dian Miller
(Owner) during a telephone conversation with Mr. Jim McDonald of the Department on February 28,
2008]

Comments: The last 12 consecutive running total VOC emissions were 4.905 tons at the end of the month
of July 2011. (August 2010 – July 2011)(see record attached)
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5. VOC RACT Emission Limiting Standards: This emission unit shall not discharge into the atmosphere
VOCs in excess of 3.5 pounds/gallon of coating, excluding water, delivered to a coating application
system. [Rule 62-296.513(2)(a)2., F.A.C.]

Comments: Seminole Machine & Welding uses 3 primers. The highest is 3.46 lbs VOC/gal, less water
and exempt solvents. The three are listed in the daily reports.
6. VOC RACT Specific Equipment Clean-up Procedure Exemption: All VOC emissions from solvent
washing shall be considered in the emission limitation of Specific Condition No. 5, unless the solvent is
directed into containers that prevent evaporation into the atmosphere. Therefore, VOC emissions from
the following are not included in the emission limitation of Specific Condition No. 5, but are included to
demonstrate compliance with Specific Condition No. 4:
A. At the end of each day the painting applicator wand is used, disconnect the wand from the
painting hose and place the wand in a sealed container.
B. Clean-up solvents from the painting hose shall be directed into containers that prevent
evaporation into the atmosphere.
[Rule 62-296.513(2)(c), F.A.C.]

Comments: A. The wand is placed in a sealed container at the end of the day, to keep it viable for use
the next day.
B. Solvent is added to the container as needed over a period of time to make–up for any loss
due to evaporation.
7. Reasonable Precautions to Control Unconfined Particulate Matter (PM) Emissions: All reasonable
precautions shall be taken to prevent and control generation of unconfined emissions of particulate matter.
These provisions are applicable to any source, including but not limited to, vehicular movement,
transportation of materials, construction, alteration, demolition or wrecking, or industrial related activities
such as loading, unloading, storing and handling. At a minimum, the following precautions shall be taken
by the permittee:
A. Curtailing operations if winds are entraining the paint overspray, and
B. Using a barrier to curtail emissions, if necessary.
[Rule 62-296.320(4)(c), F.A.C.].

Comments: Seminole Machine & Welding erected a permanent Barrier to preclude the possibility of
carry-over to adjacent properties, in case of entrainment. However, Ms. Miller stated that Seminole
Machine has instructed their operators not to paint in windy conditions, since it is self-serving, in that
they waste less paint when the winds are calm. Yet again, Seminole Machine & Welding purchased all of
the properties immediately surrounding it. (except to the North, because it is a public thruway, i.e.
Ulmerton Road).
8. Work Practice Requirements: The permittee shall not store, pump, handle, process, load, unload, or
use in any process or installation volatile organic compounds (VOC) or organic solvents (OS) without
applying known and existing vapor emission control devices or systems deemed necessary and ordered by
the Department. The following procedures shall be utilized to minimize pollutant emissions:
A. Maintain tightly fitting cover, lids, etc, on all containers of VOC/OS when they are not being
handled, tapped, etc.
B. Prevent excessive air turbulence across exposed VOC/OS.
C. Where possible and practical, procure/fabricate a tightly fitting cover for any open trough, basin,
bath, etc. of VOC/OS so that it can be covered when not in use.
D. All fittings, valve lines, etc. shall be properly maintained.
E. All VOC/OS spills shall be attended to immediately and the waste properly disposed of, recycled,
etc.
[Rule 62-296.320(1)(a), F.A.C.]
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
Comments: The EU was in compliance with A. Thru E. above.
9. Visible Emission Limitation: Visible emissions from the painting operations shall be less than 20%. In
order to provide reasonable assurance that the painting operations are being properly operated, visible
emissions due to paint overspray should not exceed 5% opacity. Exceedance of the 5% limit shall not be
considered a violation in and of itself, but an indication that additional control precautions and/or
practices may be necessary. [Rules 62-4.070(3) & 62-296.320(4)(b)1., F.A.C.]

Comments: I did not perform a Method 9, VE. The EU was not operating at the time of my visit.
10. Objectionable Odor: The permittee shall not cause, suffer, allow, or permit the discharge of air
pollutants from this plant which cause or contribute to an objectionable odor. Objectionable odor is
defined as, “Any odor present in the outdoor atmosphere which by itself or in combination with other
odors, is or may be harmful or injurious to human health or welfare, which unreasonably interferes with
the comfortable use and enjoyment of life or property, or which creates a nuisance.”
[Rules 62-296.320(2) and 62-210.200, Definitions-(Objectionable Odor), F.A.C.; Pinellas County Code,
Section 58-178; Construction Permit AC52-195852]

Comments: There were no objectionable odors outside of the facility property or on it.
11. Excess Emissions: Excess Emissions which are caused entirely or in part by poor maintenance, poor
operation, or any other equipment or process failure which may reasonably be prevented during startup,
shutdown, or malfunction shall be prohibited. [Rule 62-210.700(4), F.A.C.]

Comments: There were no episodes of excess emissions during the past 12 months, per Ms. Miller.
12. Modification Requirements: The permittee shall obtain approval from the Air Permitting Section of
the Department’s Southwest District Office prior to any physical change or change in the method of
operation of, or addition to a facility, which would result in an increase in the actual emissions.
[Rules 62-4.070(3) and 62-210.200 (Definition of Modification), F.A.C.]

Comments: There were no equipment or processes added or modified in the last 12 months, per Ms.
Miller.
13. Special Compliance Tests: When the Department, after investigation, has good reason
(such as complaints, increased visible emissions or questionable maintenance of control
equipment) to believe that any applicable emission standard contained in a Department rule or in a permit
issued pursuant to those rules is being violated, it shall require the owner or operator of the emissions unit
to conduct compliance tests which identify the nature and quantity of pollutant emissions from the
emissions unit and to provide a report on the results of said tests to the Department.
[Rule 62-297.310(7)(b), F.A.C.]

Comments: No special tests have been considered necessary or ordered.
14. Recordkeeping: In order to document compliance with Specific Condition Nos. 4 and 5, the permittee
shall maintain records which contain at a minimum the following:
A. Daily Records:
1. The rule number applicable to the operation for which the records are being maintained (i.e., Rule
62-296.513(2)(a)2., F.A.C. - Surface Coating of Miscellaneous Metal Parts and Products).
2. The application method and substrate type (i.e. spray painting on metal).
3 The amount and type of adhesive, coatings (including catalyst and reducer for multi-component
coatings), and/or solvent used at each point of application.
4. The VOC content as applied for each coating (pounds VOC/gallon of coating, excluding water, as
applied) and/or solvent (pounds VOC/gallon).
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5. The date (month, day, and year) for each application of coating and/or solvent.
6. The amount of surface preparation, clean-up, and wash-up solvent (including exempt compounds)
used and the VOC content of each (pounds VOC/gallon).
B. Monthly Records:
1. For each coating:
a. Name/description of coating.
b. VOC content of coating (pounds VOC/gallon of coating, excluding water, as applied).
c. The quantity of coating used/month (gallons).
2. For each VOC containing solvent used for surface cleaning or equipment clean-up used, on a
monthly basis:
a. Name/description of solvent.
b. VOC content of solvent (pounds/gallon).
c. The quantity of solvent used/month (gallons).
3. The calculated (based upon coating/solvent VOC content and usage) monthly total VOC emissions
(lbs./month) for:
a. Coating spray painting usage.
b. Surface cleaning and equipment clean-up solvent usage.
c. Total facility (sum of a. and b. above).
4. A calculation of the following:
a. A cumulative facility total of VOC emissions for the most recent consecutive 12-month
period, in tons.
Supporting documentation (e.g., MSDS sheets, "As Supplied" sheets, "As Applied" sheets, production
records, etc.) shall be kept for each VOC containing material used in order to provide sufficient
information to determine VOC emissions. Documentation for VOCs reclaimed, recycled or disposed,
will use a mass balance method to determine net usage. All records shall include the Facility ID,
Emission Unit ID, and Date (Month, Day, and Year) on each page. Monthly records shall be completed
within 10 days of the end of the month. Daily records shall be completed within 5 business days.
[Rules 62-4.070(3) and 62-296.500(2)(b), F.A.C.]

Comments: Record-keeping was in compliance with 1. Thru 4 above. I examined the daily records, the
monthly records and the summary sheets with the 12 month running cumulative totals. I told Ms. Miller
to keep the daily records (they are in electronic version also) but I brought back copies of the12 month
Running Consecutive Summary (RCS).
15. Reasonable Precautions Recordkeeping Requirement: In order to demonstrate compliance with the
reasonable precautions in Specific Condition No. 7, the permittee shall keep records of the periods that
painting was curtailed or barriers erected due to winds entraining the paint overspray.
[Rule 62-4.070(3), F.A.C.]
Comments: The Barriers near the spray painting area were erected circa 2002.


16. Record Retention Requirement: The daily records required by Specific Condition No. 14 shall be
recorded in a permanent form suitable for inspection by the Department and the Pinellas County
Department of Environmental Management (PCDEM) upon request and shall be retained at the facility
for a minimum of the most recent two (2) year period. [Rule 62-296.500(2)(b)1., F.A.C.]
Comments: I examined the daily records. The facility has manual daily usage records filled-out by the
operator and they are entered in a database/spreadsheet by Ms. Miller. The facility has daily, monthly
and 12 month RCS records going back several years.
17. Record Retention Requirement: The monthly records required by Specific Condition No. 14 and the
records required by Specific Condition No. 15 shall be recorded in a permanent form suitable for
inspection by the Department and the Pinellas County Department of Environmental Management
(PCDEM) upon request, and shall be retained at the facility for a minimum of the most recent three (3)
year period. [Rule 62-4.160, F.A.C.]
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Comments: The facility has daily, monthly and 12 month RCS records going back several years.
18. Annual Operating Report (AOR) Requirement: On or before March 1 of each year, submit to the Air
Compliance Sections of the PCDEM the Department's Southwest District Office, an Annual Operating
Report [DEP Form No. 62-210.900(5)] for the preceding calendar year. The report may be submitted
electronically in accordance with the instructions received with the AOR package sent by the Department,
or a hardcopy may be submitted. [Rule 62-210.370(3), F.A.C.]

Comments: The facility submitted the 2010 AOR on 3/1/2011
19. Operating Permit Renewal: An application for renewal of this operation permit shall be submitted to the
Air Permitting Section of the Southwest District Office of the Department and one application shall be
submitted to the PCDEM at least 60 days before the expiration date of this permit….

Comments: I reminded Ms. Miller that the permit will need to be renewed on or before 2/17/2013.


Valid Permit [Rule 62-210.300]

Changes to Facility/emission unit [Rule 62-210.300]
Does the emission unit description above match what the facility is operating
Comments:

Yes
C. Other:
Pollution Prevention Activities
P2 Brochure;
P2 Manual;
P2 Checklist
 P2 Handouts Provided:
 Have any emissions reductions occurred
Yes /
No
Chemical Substitution;
Equipment Changes;
Process Changes
Chemical/Material Reuse;
On-site Recycling;
Other:
Comments:
Closing Conference: I informed Ms. Miller that Seminole Machine & Welding was in compliance with
applicable rules and permit condions.
Inspector(s): Jose Rodriguez, Pinellas County, Air Quality Division
Signature(s):
ACCESS?
Date:
Date: 8/17/2011

ARMS?

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