AQ_F_0200005_20140924_PRMT_Permit

fir..
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
September 24,-2014
Mr. Steve Bruton
Director of Administration
Mitchell Gold Company
135 One Comfortable Place
Taylors-Ville,NC 28681
Subject: Air Permit No. 02815R14
Mitchell Gold Company
Hiddenite,Alexander County,North Carolina
Permit Class: Prohibitory Small
Facility ID# 0200005
Dear Mr. Bruton:
In accordance with your completed application received September 5, 2014, we are
forwarding herewith Permit No. 02815R14 to Mitchell Gold Company,Hiddenite,Alexander
County,North Carolina for the construction and operation of air emissions sources or air cleaning
devices and appurtenances. Additionally, any emissions activities determined from your air permit
application as meeting the exemption requirements contained in 15A NCAC 2Q .0102 have been
listed for information purposes as an "ATTACHMENT" to the enclosed air permit. Please note the
records retention requirements are contained in General Condition 2 of the General Conditions and
Limitations.
If any parts, requirements, or limitations contained in this permit are unacceptable to you,
you have the right to request a formal adjudicatory hearing within 30 days following receipt of this
permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of
the entire permit. This hearing request must be in the form of a written petition, conforming to G.S.
150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, 6714 Mail Service Center, Raleigh,NC 27699-6714. The form for requesting a formal
adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings.
Unless a request for a hearing is made pursuant to G.S. 15013-23,this air permit shall be final and
binding.
You may request modification of your air permit through informal means pursuant to G.S.
15013-22. This request must be submitted in writing to the Director and must identify the specific
provisions or issues for which the modification is sought. Please note that the permit will become
Mooresville Regional Office-Division of Air Quality
610 East Center Avenue,Suite 301, Mooresville,North Carolina 28115
Phone:[phone]/FAX:[phone]
Internet:www,ncdenr,.qov
An Equal Opportunity 1 Affirmative Action Employer-Made in part by recycled paper

Steve Bruton
September 24, 2014
Page 2
final and binding regardless of a request for informal modification unless a request for a hearing is
also made under G.S. 150B-23.
Unless exempted by a condition of this permit or the regulations, construction of new
air pollution sources or air cleaning devices, or modifications to the sources or air cleaning
devices described in this permit must be covered under a permit issued by the Division of Air
Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may
subject the Permittee to civil or criminal penalties as described in G.S. 143-215.114A and 143-
215.114B.
This permit shall be effective from September 24, 2014 until August 31, 2022, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations
as specified therein.
Changes have been made to the permit stipulations. The Permittee is responsible for
carefully reading the entire permit and evaluating the requirements of each permit
stipulation. The Permittee shall comply with all terms, conditions, requirements, limitations
and restrictions set forth in this permit. Noncompliance with any permit condition is grounds
for enforcement action, for permit termination, revocation and reissuance, or modification, or
for denial of a permit renewal application. Should you have any questions concerning this matter,
please contact Jennifer Womick at 704-663-1699.
Sincerely,
Ronald E. Slack,Regional Supervisor
Division of Air Quality,NCDENR
JAW
Enclosures
c: Mooresville Regional Office
0:\AQ\Shared\WPDATA\COUNTIES\ALEXANDER\00005\R14_PERMIT.docx

NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF AIR QUALITY
AIR PERMIT NO. 02815R14
Issue Date: September 24, 2014 Effective Date: September 24, 2014
Expiration Date: August 31, 2022 Replaces Permit: 02815R13
To construct and operate air emission source(s) and/or air cleaning device(s), and for the
discharge of the associated air contaminants into the atmosphere in accordance with the provisions
of Article 2 1 B of Chapter 143, General Statutes of North Carolina(NCGS) as amended, and other
applicable Laws, Rules and Regulations,
Mitchell Gold Company
375 Sharpe Lane
Hiddenite, Alexander County,North Carolina
Permit Class: Prohibitory Small
Facility ID# 0200005
(the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air
cleaning devices and appurtenances described below:
Emission Emission Source Control Control System
Source ID Description System ID —[----Description
ES-B 1 (NSPS) No.2 fuel oil/natural gas-
fired boiler(25.2 million Btu N/A N/A
per hour maximum heat
input)
wood furniture finishing operation consisting of:
ES-SBI (NESHAP), nine(9)dry filter-type spray
ES-SB2(NESHAP), booths
ES-SB3(NESHAP),
ES-SB4(NESHAP),
ES-SB5(NESHAP), N/A N/A
ES-SB6(NESHAP),
ES-SB7(NESHAP),
ES-SB8(NESHAP),
ES-SB9(NESHAP)
ES-DOI (NESHAP), two(2)steam-heated drying N/A N/A
ES-D02(NESHAP)
ES-WTI (NESHAP) two(2)washoff tanks N/A N/A
ES-WT2(NESHAP)
ES-GO(NESHAP) 1 gluing operation N/A � � N/A ~�

Permit No. 02815R14
Page 2
in accordance with the completed application 0200005.14B received September 5, 2014 including
any plans, specifications,previous applications, and other supporting data, all of which are filed
with the Department of Environment and Natural Resources, Division of Air Quality(DAQ) and are
incorporated as part of this permit.
This permit is subject to the following specified conditions and limitations including any
TESTING, REPORTING, OR MONITORING REQUIREMENTS:
A. SPECIFIC CONDITIONS AND LIMITATIONS
I. Any air emission sources or control devices authorized to construct and operate above must
be operated and maintained in accordance with the provisions contained herein. The
Permittee shall comply with applicable Environmental Management Commission
Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter
2D .0202, 2D .0503,2D .0512,2D .0516,2D .0521,2D .0524 (40 CFR 60, Subpart Dc),2D
.0535, 2D .0540, 2D .1111 (40 CFR 63, Subpart JJ), 2Q .0102, 2Q .0317 (Avoidance) and
2Q .0803.
2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee,
at least 90 days prior to the expiration date of this permit, shall request permit renewal by
letter in accordance with 15A NCAC 2Q .0304(d) and(f). Pursuant to 15A NCAC 2Q
.0203(i),no permit application fee is required for renewal of an existing air permit(without
a modification request). The renewal request(with AA application form) should be
submitted to the Regional Supervisor,DAQ. Also, at least 90 days prior to the expiration
date of this permit, the Permittee shall submit the air pollution emission inventory report
(with Certification Sheet) in accordance with 15A NCAC 2D .0202,pursuant to N.C.
General Statute 143 215.65. The report shall be submitted to the Regional Supervisor, DAQ
and shall document air pollutants emitted for the 2021 calendar year.
3. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0503
"Particulates from Fuel Burning Indirect Heat Exchangers," particulate matter emissions
from the fuel burning indirect heat exchangers shall not exceed the allowable emission rates
listed below:
Source Emission Limit
(lbs/million Btu)
No. 2 fuel oil/natural gas-fired boiler(25.2 million Btu per hour 0.472
maximum heat input) (ES-B 1)
4. PARTICULATE CONTROL REQUIREMENT- As required by 15A NCAC 2D .0512
"Particulates from Wood Products Finishing Plants," the Permittee shall not discharge
particulate matter caused by the working, sanding, or finishing of wood without providing,
as a minimum for its collection, adequate duct work and properly designed collectors, or
other such devices as approved by the Commission.

Permit No. 02815R14
Page 3
5. SULFUR DIOXIDE CONTROL REQUIREMENT-As required by 15A NCAC 2D .0516
"Sulfur'Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the
combustion sources shall not exceed 2.3 pounds per million Btu heat input.
6. VISIBLE EMISSIONS CONTROL REQUIREMENT-As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions from spray booth(ID No. ES-S135),
spray booth(ID No. ES-S138), spray booth(ID No. ES-S139), steam-heated drying oven(ID
No. ES-DO 1), steam-heated drying oven(ID No. ES-DO2),boiler(ID No. ES-B1), washoff
tank(ID No. ES-WT2) and gluing operation(ID No. ES-GO),manufactured after July 1,
1971, 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. However,
sources which must comply with 15A NCAC 2D .0524 "New Source Performance
Standards" or .1110 "National Emission Standards for Hazardous Air Pollutants" must
comply with applicable visible emissions requirements contained therein.
7. VISIBLE EMISSIONS CONTROL REQUIREMENT-As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions from spray booth(ID No. ES-S131),
spray booth(ID No. ES-S132), spray booth(ID No. ES-S133), spray booth(ID No. ES-S134),
spray booth(ID No. ES-S136) and spray booth(ID No. ES-S137), washoff tank(ID No. ES-
WTI), manufactured as of July 1, 1971, 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. However,sources which must comply with 15A NCAC 2D .0524 "New
Source Performance Standards" or .1110 "National Emission Standards for Hazardous Air
Pollutants" must comply with applicable visible emissions requirements contained therein.
8. 15A NCAC 2D .0524 "NEW SOURCE PERFORMANCE STANDARDS" - For boiler (ID
No. ES-B1), the Permittee shall comply with all applicable provisions;including the
notification,testing,reporting, recordkeeping, and monitoring requirements contained in
Environmental Management Commission Standard 15A NCAC 2D .0524 "New Source
Performance Standards" (NSPS) as promulgated in 40 CFR 60, Subpart Dc, including
Subpart A "General Provisions."
a. NSPS Reporting Requirements - In addition to any other notification requirements to
the Environmental Protection Agency (EPA),the Permittee is required to NOTIFY
the Regional Supervisor, DAQ, in WRITING, of the following:
i. The sulfur content of the distillate oil combusted in an affected source shall
not exceed 0.5 percent by weight. Within 30 days after each six-month period
of the calendar year (by January 30 for the previous six-month period
between July and December and by July 30 for the previous six-month period
between January and June),the Permittee must submit in writing to the
Regional Supervisor, DAQ,the sulfur content of the distillate oil combusted
in an affected source. If fuel supplier certification is used to demonstrate
compliance, fuel supplier certification shall include the following
information:
A. The name of the oil supplier;

Permit No. 02815RI4
Page 4
B. A statement from the oil supplier that the oil complies with the
specification under the definition of distillate oil in 40 CFR 60.41(c);
and
C. A certified statement signed by the owner or operator of an affected
source that the records of fuel supplier certification submitted
represent all of the fuel combusted during the reporting period.
b. NSPS Recordkeeping Requirements - In addition to any other recordkeeping
requirements of the EPA,the Permittee is required to maintain records as follows:
i. The amounts of each fuel combusted during each month; and
ii. All records required under this section shall be maintained for a period of two
years following the date of such record.
c. NSPS Emissions Limitations -As required by 15A NCAC 2D .0524,the following
permit limits shall not be exceeded:
Affected Source(s) Pollutant Emission
Limit
No. 2 fuel oil/natural gas-fired boiler(25.2 million Btu Sulfur 0.5%by
per hour maximum heat input) (ES-B1) content weight
9. NOTIFICATION REQUIREMENT -As required by 15A NCAC 2D .0535,the Permittee of
a source of excess emissions that last for more than four hours and that results from a
malfunction, a breakdown of process or control equipment or any other abnormal
conditions, shall:
a. Notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time
of the Division's next business day of becoming aware of the occurrence and
describe:
i. the name and location of the facility,
ii. the nature and cause of the malfunction or breakdown,
iii. the time when the malfunction or breakdown is first observed,
iv. the expected duration, and
V. an estimated rate of emissions.
b. Notify the Director or his designee immediately when the corrective measures have
been accomplished.
This reporting requirement does not allow the operation of the facility in excess of
Environmental Management Commission Regulations.

Permit No. 02815R14
Page 5
10. FUGITIVE DUST CONTROL REQUIREMENT -As required by 15A NCAC 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. If substantive complaints or excessive fugitive
dust emissions from the facility are observed beyond the property boundaries for six minutes
in any one hour(using Reference Method 22 in 40 CFR,Appendix A),the owner or
operator may be required to submit a fugitive dust plan as described in 2D .0540(f).
"Fugitive dust emissions" means particulate matter that does not pass through a process
stack or vent and that is generated within plant property boundaries from activities such as:
unloading and loading areas,process areas stockpiles, stock pile working, plant parking lots,
and plant roads(including access roads and haul roads).
11. 15A NCAC 2D .I 111 "MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY" -The
wood furniture manufacturing operations spray booth(ID No. ES-SB1), spray booth(ID No.
ES-S132), spray booth(ID No. ES-S133), spray booth(ID No. ES-S134), spray booth(ID No.
ES-S135), spray booth(ID No. ES-S136), spray booth(ID No. ES-S137), spray booth (ID No.
ES-S138), spray booth(ID No. ES-S139), steam-heated drying oven(ID No. ES-DO1),
steam-heated drying oven(ID No. ES-D02), washoff tank (ID No. ES-WTI), washoff tank
(ID No. ES-WT2) and gluing operation(ID No. ES-GO)shall comply with all requirements
of 15A NCAC 2D .1111 "Maximum Achievable Control Technology" and 40 CFR Part 63,
Subpart JJ "National Emission Standards for Wood Furniture Manufacturing Operations."
[40 CFR 63.800]
Re ulated Material Emission Limitation
Thinners 10%by weight HAP
stains, washcoats, sealers,topcoats, basecoats,
1.0 lb VHAP/lb solids, as applied
and enamels
washcoat,basecoat, or enamel formulated coatings - 1.0 lb VHAP/lb solids
onsite thinners- 3.0%by weight VHAP
strip able spray booth coatings 0.8 lb VOC_per_lb solids, as applied
foam contact adhesives used in products
which meet flammability requirements per
California Technical Bulletin 116, 117, or
133,the Business and Institutional Furniture 1.81b VHAP per lb solids, as applied
Manufacturers Association's (BIFMA's)X5.7,
UFAC flammability testing, or any similar
requirements from local, State,or Federal fire
regulatory agencies
all other contact adhesives 1.0 lb VHAP/solids, as applied
1.0%by weight formaldehyde or 400 pounds
coatings and contact adhesives formaldehyde emissions per rolling 12-month
period
a. Definitions and Nomenclature - For the purpose of this permit condition,the
definitions and nomenclature contained in 40 CFR 63.801 shall apply.

Permit No. 02815RI4
Page 6
b. Regulated Pollutants -Volatile Hazardous Air Pollutants (VHAPs) and Volatile
Organic Compounds(VOCs) as defined in 40 CFR 63.801.
c. General Provisions-The Permittee shall comply with the requirements of 40 CFR
Part 63, Subpart A "General Provisions," according to the applicability of Subpart A
to such sources, as identified in Table 1 of 40 CFR Part 63, Subpart JJ.
d. Work Practice Standards -The Permittee shall adhere to the work practice standards
as specified by 40 CFR 63.803.
e. Recordkeeping Requirements - The Permittee shall prepare,maintain, and follow a
written work practice implementation plan in accordance with 40 CFR 63.806(e)that
defines environmentally desirable work practices for each wood furniture
manufacturing operation and addresses each of the work practice standards specified
below:
i. Operator Traini g- in accordance with 40 CFR 63.803(b);
ii. Inspection and Maintenance Plan-in accordance with 40 CFR 63.803(c);
iii. Cleaning and Washoff Solvent Accounting_System- in accordance with 40
CFR 63.803(d);
iv. Chemical Composition of Cleaning and Washoff Solvents - in accordance
with 40 CFR 63.803(e);
V. Spray Booth Cleaning- in accordance with 40 CFR 63.803(f);
vi. Storage Requirements - in accordance with 40 CFR 63.803(g);
vii. Application Equipment Requirements - in accordance with 40 CFR
63.803(h); Effective November 21,2014 conventional air spray guns are
allowed only when emissions are vented to a control device;
viii. Line Cleaning- in accordance with 40 CFR 63.803(i);
ix. Gun Cleaning - in accordance with 40 CFR 63.8030);
X. Washoff Operations - in accordance with 40 CFR 63.803(k); and
xi. Formulation Assessment Plan _in accordance with 40 CFR 63.803(l).
£ Reporting_Requirements -The Permittee shall submit the compliance status report to
the Regional Supervisor by in accordance with 40 CFR 63.804(f)(8) and 40 CFR
63.807(b). The Permittee shall submit semi-annual reports to the Regional
Supervisor in accordance with 40 CFR 63.804(g)(8) and 40 CFR 63.807(c). The
Permittee shall follow the reporting requirements in 40 CFR 63.807(e) as required
and 40 CFR 63.807(a) following the applicability criteria in 40 CFR 63.800(d).

Permit No. 02815R14
Page 7
g. Finishing Operations -Per 40 CFR 63.804(a)(4),the Permittee has chosen to use
both the compliant coatings and the facility averaging compliance options for the
finishing operations spray booths (ID Nos. ES-SB3,ES-SB5, ES-SB8,ES-SB9,ES-
SB1, ES-SB7, ES-SB6, ES-SB4 and ES-SB2), drying ovens (ID Nos. ES-D02 and
ES-DO1), washoff tanks (ID Nos. ES-WT1 and ES-WT2) and gluing operation(ID
No. ES-GO). Compliance with each of these options is considered a separate
ALTERNATIVE OPERATING SCENARIO (AOS) and the Permittee,
contemporaneously with making a change from one AOS to another, shall record in
a log the scenario under which it is operating. Records shall be retained for five
years. [15A NCAC 2Q .0508(p)]
AOSI: Compliant Coatings Option
i. Emission Limits -The Permittee shall comply with all provisions of 40 CFR
63.802(a)(1) and 63.804(a)(2) as applicable to the finishing operations spray
booths (ID Nos. ES-SB3, ES-SB5,ES-SB8, ES-SB9, ES-SB1,ES-SB7,ES-
SB6, ES-SB4 and ES-SB2), drying ovens(ID Nos. ES-D02 and ES-DO1),
washoff tanks (ID Nos. ES-WT1 and ES-WT2) and gluing operation(ID No.
ES-GO). All thinners, stains, washcoats, sealers,topcoats, basecoats, and
enamels used at the facility shall meet the emission limitations as detailed in
the following table:
Re ulated Material Emission Limitation
Thinners 10%by weight HAP
stains,washcoats, sealers,topcoats,basecoats, 1.0 lb VHAP/lb solids, as
and enamels applied
coatings - 1.0 lb VHAP/lb
washcoat' basecoat, or enamel formulated onsite solids
, thinners- 3.0%by weight
VHAP
ii. Compliance Procedures and Monitoring Requirements - Emission sources
spray booths(ID Nos. ES-SB3, ES-SB5, ES-SB8, ES-SB9, ES-SB1, ES-SB7,
ES-SB6, ES-SB4 and ES-SB2), drying ovens (ID Nos. ES-D02 and ES-
DO1), washoff tanks (ID Nos. ES-WT1 and ES-WT2) and gluing operation
(ID No. ES-GO) are using both non-continuous and continuous coaters. The
Permittee shall demonstrate that only compliant thinners are used and that all
stains,washcoats, sealers,topcoats,basecoats, and enamels,are compliant,as
applied, in accordance with 40 CFR 63.804(g)(2) for non-continuous coaters
and 40 CFR 63.804(g)(3) for continuous coaters.
iii. Performance Test Method- EPA Method 311 [Appendix A of 40 CFR Part
63] shall be used to determine the V.HAP content of liquid coatings in
accordance with 40 CFR 63.805(a).
iv. Recordkeeping Requirements - The Permittee shall keep records in
accordance with 40 CFR 63.806(a)following the applicability criteria in 40

Permit No. 02815R14
Page 8
CFR 63.800(d), 40 CFR 63.804(g)(2),40 CFR 63.806(b)(1) and(b)(2), 40
CFR 63.806(h), 40 CFR 63.806(i), and 40 CFR 63.8060).
V. Reporting Requirements - The Permittee shall submit the compliance stats
report to the Regional Supervisor by in accordance with 40 CFR 63.804(f)(7)
and 40 CFR 63.807(b). The Permittee shall submit semi-annual reports to the
Regioiiaf Supervisor in accordance with 40 CFR 63.804(g)(7) and 40 CFR
63.807(c). The Permittee shall follow the reporting requirements in 40 CFR
63.807(a) following the applicability criteria in 40 CFR 63.800(d).
AOS2: Facility Averaging Option
vi. Emission Limits -The Permittee shall comply with all provisions of 40 CFR
63.802(a)(1) and 63.804(a)(1) as applicable to the finishing operations spray
booths (ID Nos. ES-SB3, ES-SB5, ES-SB8,ES-S139, ES-SB1, ES-SB7,ES-
SB6,ES-SB4 and ES-SB2), drying ovens(ID Nos. ES-D02 and ES-D01),
washoff tanks (ID Nos. ES-WT1 and ES-WT2) and gluing operation(ID No.
ES-GO). The weighted average VHAP content across all coatings, as applied,
shall not exceed 1.0 kg VHAP per kg solids.
vii. Compliance Procedures and Monitoring Requirements - The Permittee shall
demonstrate that the monthly average VHAP content for all finishing
materials used at the facility is no greater than 1.0 kg VHAP per kg solids, as
applied, in accordance with 40 CFR 63.803(g)(1).
viii. Performance Test Method - EPA Method 311 [Appendix A of 40 CFR Part
63] shall be used to determine the VHAP content of liquid coatings in
accordance with 40 CFR 63.805(a).
ix. Recordkeeping Requirements - Permittee shall keep records in accordance
with 40 CFR 63.806(a) following the applicability criteria in 40 CFR
63.800(d), 40 CFR 63.804(g)(1), 40 CFR 63.806(b)(1) and (b)(2), 40 CFR
63.806(c), 40 CFR 63.806(h), 40 CFR 63.806(i), and 40 CFR 63.8060).
X. Reporting Requirements -The Permittee shall submit the compliance status
report to the Regional Supervisor by in accordance with 40 CFR 63.804(f)(7)
and 40 CFR 63.807(b). The Permittee shall submit semi-annual reports to the
Regional Supervisor in accordance with 40 CFR 63.804(g)(7) and 40 CFR
63.807(c). The Permittee shall follow the reporting requirements in 40 CFR
63.807(a) following the applicability criteria in 40 CFR 63.800(d).
h. Cleaning Operations -
i. Emission Limits -The Permittee shall comply with the limits of 40 CFR
63.802(a)(3) applicable to the strippable spray booth operations spray booths
(ID Nos. ES-SB3,ES-SB5, ES-SB8, ES-S139,ES-SB1,ES-SB7, ES-SB6,
ES-SB4 and ES-SB2), drying ovens(ID Nos. ES-D02 and ES-D01),
washoff tanks (ID Nos. ES-WT1 and ES-WT2) and gluing operation(ID No.
ES-GO) as detailed in the following table:

Permit No. 02815R14
Page 9
Regulated Material Emission Limitation
strippable spray booth coatings 0.8 lb VOC per lb solids, as applied
ii. Compliance Procedures and Monitoring Requirements - When the emission
source is using foam and other contact adhesives,the Permittee shall
demonstrate that only compliant adhesives are used in accordance with 40
CFR 63.804(g)(5).
iii. Performance Test Method- EPA Method 311 [Appendix A of 40 CFR Part
63] shall be used to determine the VHAP content of liquid coatings in
accordance with 40 CFR 63.805(a).
iv. Recordkeeping Requirements - The Permittee shall keep records in
accordance with 40 CFR 63.806(a) following the applicability criteria in 40
CFR 63.800(d), 40 CFR 63.806(b)(1) and(b)(3), 40 CFR 63.806(h), 40 CFR
63.806(i),and 40 CFR 63.8060).
V. Reporting Requirements - The Permittee shall submit the compliance status
report to the Regional Supervisor by in accordance with 40 CFR 63.804(f)(7)
and 40 CFR 63.807(b). The Permittee shall submit semi-annual reports to the
Regional Supervisor in accordance with 40 CFR 63.804(g)(1) and 40 CFR
63.807(c). The Permittee shall follow the reporting requirements in 40 CFR
63.807(a) following the applicability criteria in 40 CFR 63.800(d).
i. Contact Adhesive Operations -
i. Emission Limits - The Permittee shall comply with all provisions of 40 CFR
63.802(a)(2) and 63.804(b) and(c) as applicable to the contact adhesive
operations spray booths (ID Nos. ES-S133,ES-SBS, ES-SBB, ES-S139, ES-
SB 1, ES-SB7, ES-S136, ES-S134 and ES-SB2), drying ovens (ID Nos. ES-
D02 and ES-DO I), washoff tanks (ID Nos. ES-WT1 and ES-WT2) and
gluing operation (ID No. ES-GO) as detailed in the following table:
Regulated Material ` Emission
Limitation
foam contact adhesives used in products which meet 1.8 lb VHAP
flammability requirements per California.Technical Bulletin per lb solids,
116, 117, or 133,the Business and Institutional Furniture as applied
Manufacturers Association's (BIFMA's)X5.7,UFAC
flammability testing, or any similar requirements from local,
State, or Federal fire regulatory agencies
all other contact adhesives 1.0 lb
HAP/lb
solids, as
pp lied

Permit No. 02815RI4
Page 10
ii. Compliance Procedures and Monitoring Requirements - When the spray
booths (ID Nos. ES-S133, ES-SB5, ES-S138, ES-SB9, ES-SB1,ES-S137,ES-
SB6, ES-SB4 and ES-SB2), drying ovens (ID Nos. ES-D02 and ES-DO I),
washoff tanks (ID Nos. ES-WTI and ES-WT2) and gluing operation(ID No.
ES-GO) is using foam and other contact adhesives. The Permittee shall
demonstrate that only compliant thinners are used and that all stains,
washcoats, sealers,topcoats, basecoats,aria enamels, are compliant, as
applied, in accordance with 40 CFR 63.804(g)(5).
iii. Performance Test Method- EPA Method 311 [Appendix A of 40 CFR Part
63] shall be used to determine the VHAP content of liquid coatings in
accordance with 40 CFR 63.805(a).
iv. Recordkeeping Requirements -The Permittee shall keep records in
accordance with 40 CFR 63.806(a) following the applicability criteria in 40
CFR 63.800(d), 40 CFR 63.806(b)(1) and(b)(2), 40 CFR 63.806(h), 40 CFR
63.806(i), and 40 CFR 63.8060).
V. Reporting Requirements-The Permittee shall submit the compliance status
report to the Regional Supervisor by in accordance with 40 CFR 63.804(f)(5)
and 40 CFR 63.807(b). The Permittee shall submit semi-annual reports to the
Regional Supervisor in accordance with 40 CFR 63.804(g)(5) and 40 CFR
63.807(c). The Permittee shall follow the reporting requirements in 40 CFR
63.807(a) following the applicability criteria in 40 CFR 63.800(d).
j. Formaldehyde Requirements - The permittee shall comply with one of the following
two options by November 21, 2014 and thereafter:
i. Option#1 400 pounds formaldehyde limit per rolling 12 month period)-
A. Emissions Limits In accordance with 40 CFR 63.802(a) and (b),
limit total formaldehyde (Ftotal)use in coatings and contact adhesives
to no more than 400 pounds per rolling 12 month period.
B. Compliance Procedures and Monitoring Requirements - In
accordance with 40 CFR 63.804(h), calculate total formaldehyde
emissions from all finishing materials and contact adhesives used at
the facility using Equation 5 and maintain a value of Ftotal no more
than 400 pounds per rolling 12 month period.
C. Recordkeeping Requirements - In accordance with 40 CFR 63.806(b),
the Permittee shall keep records of the formaldehyde content, in
pounds per gallon,as applied, of each finishing material and contact
adhesive subject to the emission limits of 40 CFR 63.802(a) and(b).
D. Reporting Requirements -The Permittee shall submit semi-annual
reports to the Regional Supervisor in accordance with 40 CFR
63.807(c).

Permit No. 02815R14
Page 11
ii. Option#2 (CPDS < 1.0%by weight formaldehyde) -
A. Emissions Limits - In accordance with 40 CFR 63.802(a) and (b), use
coatings and contact adhesives only if they are low-formaldehyde
coatings and adhesives, in.any wood furniture manufacturing
operations. Low formaldehyde means, in the context of a.coating or
contact adhesive, a product concentration of less than or equal to 1.0
percent formaldehyde by weight, as described in a certified product
data sheet for the material.
B. Compliance Procedures and Monitoring Requirements - In
accordance with 40 CFR 63.804(h), demonstrate compliance by use
of coatings and contact adhesives only if they are low formaldehyde
coatings and contact adhesives maintaining a certified product data
sheet for each coating and contact adhesive used and submitting a
compliance certification with the semi-annual report..
C. Recordkeeping Requirements - In accordance with 40 CFR 63.806(b),
the Permittee shall keep a certified product data sheet for each coating
and contact adhesive used.
D. Reporting Requirements - The Permittee shall submit semi-annual
reports to the Regional Supervisor in accordance with 40 CFR 40
CFR 63.807(c) and 40 CFR 63.804(h). The compliance certification
shall state that low-formaldehyde coatings and contact adhesives, as
applicable, have been used each day in the semiannual reporting
period or should otherwise identify the periods of noncompliance and
the reasons for noncompliance. An affected source is in violation of
the standard whenever a coating or contact adhesive that is not low-
formaldehyde, as demonstrated.by records or by a sample of the
coating or contact adhesive, is used. Use of a noncompliant coating or
contact adhesive is a separate violation for each day the noncompliant
coating or contact adhesive is used. The compliance certification shall
be signed by a responsible official of the company that owns or
operates the affected source.
12. Federal and State Rules Applicable to Sources Exempted from Air Permitting Requirements
- Your facility is subject to the following federal and state rules:
40 CFR 63 -NESHAP/MACT-- Subpart ZZZZ -- Reciprocating Internal
Combustion Engines
which are applicable to some of the emission sources at your facility listed on the
"Insignificant/Exempt Activities" list attached to this permit. The purpose of this permit
condition is to inform you of your compliance obligations to these applicable rules as they
are enforceable.

Permit No. 02815R14
Page 12
13. AVOIDANCE CONDITION FOR AREA SOURCES SUBJECT TO 40 CFR 63 Subs
JJJJJJ 6J - In accordance with 15A NCAC 2Q .0317,the Permittee is avoiding
applicability of 40 CFR 63 Subpart JJJJJJ (0) "Industrial, Commercial, and Institutional
Boilers Area Sources." The Permittee is permitted to operate a natural gas/No. 2 fuel oil-
fired boiler (ID Nos. ES-131). Per 40 CFR 63.1.1195(e),these/this source(s) is/are exempt
from this Subpart because they are defined as gas-fired boiler(s) in 40 CFR 63.11237. In
order to maintain this exemption,the Permittee is allowed to fire liquid fuel only during
periods of gas curtailment, gas supply interruptions, startups, or for periodic testing on liquid
fuel (periodic testing not to exceed a combined total of 48 hours during any calendar year).
a. The Permittee shall maintain records that document the time periods when liquid fuel
is fired and the reasons the liquid fuel is fired.
b. If the Permittee fires liquid fuel for reasons other than gas curtailment, gas supply
interruptions, startups, or for periodic testing on liquid fuel,the Permittee is no
longer exempt from Subpart JJJJJJ (6J). As required by 40 CFR 62.11225(g),the
Permittee must provide notice within 30 days of the fuel switch. The notification
must identify:
i. The name of the owner or operator of the affected source,the location of the
source,the boiler(s) that have switched fuels, and the date of the notice.
ii. The date upon which the fuel switch occurred.
As required by 40 CFR 63.11210(h),the Permittee must demonstrate
compliance within 180 days of the effective date of the fuel switch.
14. EXCLUSIONARY RULE REQUIREMENTS -'Pursuant to 15A NCAC 2Q .0803 "Coating,
Solvent Cleaning, and Graphic Arts," potential emissions shall be determined using actual
emissions without accounting for any air pollution control devices.
a. As required by 15A NCAC 2Q .0803,the facility potential emissions (defined as
actual emissions) shall be less than the following:
i. 100 tons per year of volatile organic compounds (VOC);
1 10 tons per year of each hazardous air pollutant(HAP); and
iii. 25 tons per year of all HAPs combined.

Permit No. 02815R14
Page 13
b. As required by 15A NCAC 2Q .0803,the Permittee shall comply with the following
requirements:
i. Annual Report Requirement- By March 1 of each year, regardless of the
actual emissions,the Permittee shall submit to the Regional Supervisor,
DAQ, a report summarizing emissions of VOC and HAPs containing the
following:
A. the pounds of VOC used during the previous calendar year;
B. the greatest quantity in pounds of an individual HAP used during the
previous calendar year; and
C. the total pounds of all HAPs used during the previous calendar year.
ii. Records Maintenance Requirement- The Permittee shall maintain purchase
orders and invoices of materials containing VOC. These purchase orders and
invoices shall be maintained for a period of at least three years and be made
available to DAQ personnel upon request.
iii. Notification Requirement- The Permittee shall report to the Regional
Supervisor, DAQ, any exceedance of a requirement of rule 15A NCAC 2Q
.0803 within one week of occurrence; and
iv. Certification Requirement- The Permittee shall certify all submittals as to the
truth, completeness, and accuracy of all information recorded and reported
over the signature of the appropriate official as identified in rule 15A NCAC
2Q .03040) "Applications."
Compliance with the recordkeeping and reporting requirements contained in this specific
condition shall not relieve the Permittee from the requirement to have a Title V permit if the
actual emissions from the facility exceed 100 tons per year of VOC, or 10 tons per year of
an individual HAP, or 25 tons per year of all HAPs combined.
B. GENERAL CONDITIONS AND LIMITATIONS
1. In accordance with G.S. 143-215.108(c)(1), TWO COPIES OF ALL DOCUMENTS,
REPORTS, TEST DATA, MONITORING DATA,NOTIFICATIONS, REQUESTS FOR
RENEWAL, AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall
be submitted to the:
Regional Supervisor
North Carolina Division of Air Quality
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville,NC 28115
704-663-1699

Permit No. 02815R14
Page 14
For identification purposes, each submittal should include the facility name as listed on the
permit,the facility identification number, and the permit number.
2. RECORDS RETENTION REQUIREMENT- In accordance with 15A NCAC 2D .0605,
any records required by the conditions of this permit shall be kept on site and made available
to DAQ personnel for inspection upon request. These records shall be maintained in a form
suitable and readily available for expeditious inspection and review. These records must be
kept on site for a minimum of 2 years,unless another time period is otherwise specified.
3. ANNUAL FEE PAYMENT - Pursuant to 15A NCAC 2Q .0203(a),the Permittee shall pay
the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a
timely manner will cause the DAQ to initiate action to revoke the permit.
4. EQUIPMENT RELOCATION - In accordance with 15A NCAC 2Q .0301, a new air permit
shall be obtained by the Permittee prior to establishing,building, erecting, using, or
operating the emission sources or air cleaning equipment at a site or location not specified in
this permit.
5. REPORTING REQUIREMENT - In accordance with 15A NCAC 2Q .0309, any of the
following that would result in previously unpermitted, new, or increased emissions must be
reported to the Regional Supervisor, DAQ:
a. changes in the information submitted in the application regarding facility emissions;
b. changes that modify equipment or processes of existing permitted facilities;-or
c. changes in the quantity or quality of materials processed.
If appropriate,modifications to the permit may then be made by the DAQ to reflect any
necessary changes in the permit conditions. In no case are any new or increased emissions
allowed that will cause a violation of the emission limitations specified herein.
6. In accordance with 15A NCAC 2Q .0309,this permit is subject to revocation or
modification by the DAQ upon a determination that information contained in the application
or presented in the support thereof is incorrect, conditions under which this permit was
granted have changed, or violations of conditions contained in this permit have occurred. In
accordance with G.S. 143-215.108(c)(1),the facility shall be properly operated and
maintained at all times in a manner that will effect an overall reduction in air pollution.
Unless otherwise specified by this permit, no emission source may be operated without the
concurrent operation of its associated air cleaning device(s) and appurtenances.
7. In accordance with G.S. 143-215.108(c)(1),this permit is nontransferable by the Permittee.
Future owners and operators must obtain a new air permit from the DAQ.
8. In accordance with G.S. 143-215.108(c)(1),this issuance of this permit in no way absolves
the Permittee of liability for any potential civil penalties which may be assessed for
violations of State law which have occurred prior to the effective date of this permit.

Permit No. 02815RI4
Page 15
9. In accordance with G.S. 143-215.108(c)(1),this permit does not relieve the Permittee of the
responsibility of complying with all applicable requirements of any Federal, State, or Local
water quality or land quality control authority.
10. In accordance with 15A NCAC 2D .0605, reports on the operation and maintenance of the
facility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such
intervals and in such form and detail as may be required by the DAQ. Information required
in such reports may include,but is not limited to,process weight rates, firing rates,hours of
operation, and preventive maintenance schedules.
11. A violation of any term or condition of this permit shall subject the Permittee to enforcement
pursuant to G.S. 143-215.114A, 143-215.114B, and 143-215.114C, including assessment of
civil and/or criminal penalties.
12. Pursuant to North Carolina General Statute 143-215.3(a)(2), no person shall refuse entry or
access to any authorized representative of the DAQ who requests entry or access for
purposes of inspection, and who presents appropriate credentials, nor shall any person
obstruct,hamper, or interfere with any such representative while in the process of carrying
out his official duties. Refusal of entry or access may constitute grounds for permit
revocation and assessment of civil penalties..
.13. In accordance with G.S. 143-215.108(c)(1), the Permittee must comply with any applicable
Federal, State, or Local requirements governing the handling, disposal, or incineration of
hazardous, solid, or medical wastes, including the Resource Conservation and Recovery Act
(RCRA) administered by the Division of Waste Management.
14. PERMIT RETENTION REQUIREMENT - In accordance with 15ANCAC 2Q .0110,the
Permittee shall retain a current copy of the air permit at the site. The Permittee must make
available to personnel of the DAQ, upon request,the current copy of the air permit for the
site.
15. CLEAN AIR ACT SECTION 112(r) REQUIREMENTS- Pursuant to 15ANCAC 2D .2100
"Risk Management Program," if the Permittee is required to develop and register a risk
management plan pursuant to Section 112(r) of the Federal Clean Air Act, then the
Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part
68.
16. PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY - Pursuant to Title I
Part A Section 112(r)(1) of the Clean Air Act "Hazardous Air Pollutants - Prevention of
Accidental Releases -Purpose and General Duty," although a risk management plan may not
be required, if the Permittee produces, processes, handles, or stores any amount of a listed
hazardous substance,the Permittee has a general duty to take such steps as are necessary to
prevent the accidental release of such substance and to minimize the consequences of any
release. This condition is federally-enforceable only.

Permit No. 02815R14
Page 16
17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS - If emissions
testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing
to the DAQ in support of a permit application or to demonstrate compliance,the Permittee
shall perform such testing in accordance with 15A NCAC 2D .2600 and follow all DAQ
procedures including protocol approval,regional notification,report submittal, and test
results approval.
Permit issued this the 24t' of September, 2014.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
L
Ronal E. Slack
Regional Supervisor
By Authority of the Environmental Management Commission
Air Permit No. 02815R14

ATTACHMENT to Permit No. 02815RI4, September 24, 2014
Insignificant/Exempt Activities
Source Exemption Source of Source of Title V
Regulation TAPS? Pollutants?
IES-1 - diesel-fired pump (220 hp) for the FcQ
fire suppression system (subject to MACT, (111) Yes Yes
Subpart ZZZZ)
1. Because an activity is exempted from being required to have a permit or permit modification
does not mean'that the activity is exempted from an applicable requirement or that the owner
or operator of the source is exempted from demonstrating compliance with any applicable
requirement.
2. When applicable, emissions from stationary source activities identified above shall be
included in determining compliance with the permit requirements for toxic air pollutants
under 15A NCAC 2D .1100 "Control of Toxic Air Pollutants" or 2Q .0711 "Emission Rates
Requiring a Permit."

'i