AQ_F_1800575_20181107_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Snyder Paper Corporation-Conover
NC Facility ID 1800575
Inspection Report County/FIPS: Catawba/035
Date: 11/07/2018
Facility Data Permit Data
Snyder Paper Corporation-Conover Permit 10467/R00
409 Thornburg Drive Issued 10/21/2015
Conover,NC 28613 Expires 9/30/2023
Lat: 35d 42.5949m Long: 81d 12.0312m Classification Small
SIC: 3086/Plastics Foam Products Permit Status Active
NAICS: 32614/Polystyrene Foam Product Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Jeff Aliberti Gary Franklin Steve Bumgardner MACT Part 63: Subpart 60
Facilities Manager CEO Vice President
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 11/07/2018
Q_ a� A Inspector's Name Robert Papuga
Inspector's Signature:l . � �J Operating Status Operating
���lll ��V Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: 1 1 S_ Z p 1 IF On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
No emissions inventory on record.The emissions inventory is due 07/02/2023.
*Highest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

Snyder Paper Corporation—Conover
November 07.2018
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Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 11/09/2018 _IBEAM INFO,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 checked _IBEAM Complaint
X IBEAM Planning,Next Inspection Date
11/01/2020
Directions: From MRO, travel I-77 North to I-40 West to Hickory. Take Exit 133 (Rock Barn Road). At
the top of the ramp turn left and travel to Thornburg Drive. Turn left onto Thornburg Drive. The facility
is on the left at 409 Thornburg Drive.
Safety Equipment: Safety shoes are recommended.
Safety Issues: None.
Lat/Lon- Coordinates: A review of the facility's coordinates on Google maps indicates the facility
latitude and longitude coordinates are accurate. No changes to the latitude and longitude coordinates of
this facility in IBEAM are needed.
Email Contacts: IBEAM contacts were verified. The technical contact was updated in IBEAM.
1. The purpose of this site visit was to conduct a routine air quality inspection. This facility
manufactures foam cushions for the furniture industry. The facility is currently operating 40 hours
per week with 35 employees. Mr.Jeff Aliberti, Corporate Facilities&Fleet Manager,'
accompanied me during this inspection.
2. Facility Contact Information:
During the inspection, I verified the facility contact information in IBEAM. The Technical
Contact Data was updated in IBEAM.
3. Compliance History:
No problems have been noted by DAQ prior to this visit. The current compliance status is
discussed in the following sections.

Snyder Paper Corporation—Conover
November 07.2018
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4. Observations of permitted air emission sources and control devices:
Emission Emission Source Control
Source ID Description System ID
NESHAP two (2) foam gluing lines
GL-01 equipped with dry filters N/A
GL-02
i
I
,Observed: Adhesive is used to glue foam to foam and foam to polyester batting to produce cushions for
,the furniture industry. The gluing stations consist of small individual booths/tables with a spray gun.
Overspray is controlled by a foam/fiber filter on each booth which gets changed daily or every other day
depending on the operator. The plant has two glue lines. The spray guns were in various levels of
operation during this inspection. The gluing process is subject to the Flexible Polyurethane Foam
Production and Fabrication GACT (40 CFR Part 63 Subpart 000000). The facility maintains a
istatement that it uses no methylene chloride in the foam adhesives.
F-01 solvent cleaning operation
......................................................_............................................................................................................._................................_.............................................................................................._........................................__........................................................._..._....._........... ....................................__...._......
;Observed: Containers were properly closed. No spills were observed.
5. Observations of insij4nificant air emission sources and control devices listed on the current
p t.
None.
6. Observations of air emission sources and control devices not listed on the current permit:
None noted.
7. Compliance with specific permit conditions and limitations:
a. Condition A.3 15A NCAC 2D .0515 "Particulates from Miscellaneous Industrial
Processes," particulate matter emissions from the emission sources shall not exceed
allowable emission rates.
Observed. The dry filters used appeared to be in good condition. Because the glue is
applied directly to the foam the amount of overspray is minimal. Compliance with this
permit condition was indicated.
b. Condition A.4. 15A NCAC 2D .0521, "Control of Visible Emissions". The facility is
limited to 20 percent opacity.
Observed. No visible emissions were observed at the facility. Compliance with this
stipulation is indicated.
c: Condition A.5. 15A NCAC 2D .0535. 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 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.

Snyder Paper Corporation—Conover
November 07. 2018
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Observed. Based on a conversation with Mr. Alberti,no excess emissions have occurred
at the facility. Compliance with this stipulation is indicated.
d. Condition A.6 15A NCAC 2D .0540 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.
Observed. MRO DAQ has not received any fugitive dust emissions complaints
regarding this facility. This company has paved roads at this facility. During the
inspection, I observed no fugitive dust or visible emissions from this facility.
Compliance with this stipulation is indicated.
e. Condition A.7. 15A NCAC 2D .0958 "Work Practices for Sources of Volatile Organic
Compounds", the facility is required to store all VOC-containing material in closed
containers when not in use, clean spills and equipment properly.
Observed. Adhesive containers were properly closed with tightly fitting lids and no
defects found in the containers or lids. During the inspection,I observed no open
containers, spills or any other cleaning operations being conducted at this facility.
Compliance with this stipulation is indicated. This rule no longer applies since Catawba
County has been re-designated as attainment for ozone.
f. Condition A.8-For the Flexible polyurethane foam fabrication operations, the emission
sources,the Permittee shall comply with NESHAP Subpart 000000 for"Flexible
Polyurethane Foam Production and Fabrication Area Sources".
a. Standards and Compliance-Pursuant to 40 CFR 63.11416 the following standards
shall apply:
i. The Permittee shall not use any adhesive containing methylene chloride in a
flexible polyurethane foam fabrication process.
b. Recordkeeping Requirements -Pursuant to 40 CFR 63.11417 the following
recordkeeping requirements shall apply:
i. For foam fabrication operations with loop slitters, the Permittee shall retain
on site a statement signed and dated by a responsible official stating that the
facility does not use any adhesive containing methylene chloride in a
flexible polyurethane foam fabrication process.
ii. The Permittee shall demonstrate compliance with the requirements of
paragraph a.i. of this condition using adhesive usage records,Material
Safety Data Sheets or engineering calculations.

Snyder Paper Corporation—Conover
November 07.2018
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iii. The Permittee shall retain the records used to demonstrate compliance for
five years with the last two years of data retained on site. The remaining
three years of data may be retained off site.
Observed. The facility maintains a statement that it uses no methylene chloride in the
foam adhesives. I also verified that the adhesives SIDS did not contain methylene
chloride. Compliance with this condition is indicated.
8. NSPS/NESHAP Review
The facility is subject to the NESHAP Subpart 000000 for "Flexible Polyurethane Foam
Production and Fabrication Area Sources". This facility does not use any glue that contains
methylene chloride. The facility has no gasoline storage tanks, boilers or engines and does not
appear to be subject to any additional NESHAPs.
9. Summary of changes needed to the current permit:
2D .0958 no longer applies since Catawba County has been re-designated as attainment. The
electronic yellow sheet for permit changes needed has been completed and placed in the facility's
electronic file.
10. Compliance assistance offered during the inspection:
None.
11. Section 112(r) applicability:
This facility does not appear to be subject to the requirements of the Chemical Accident Release
Prevention Program, Section 112(r) of the Clean Air Act.
12. Compliance determination:
Based on my observations, this facility appeared to be in compliance with the applicable air
quality regulations at the time of the inspection.
RJP:Ihe
cc: MRO File
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