AQ_F_1800513_20190109_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Hickory Springs Mfg.Co.dba HSM-Hickory
Fabrication
Inspection Report NC Facility ID 1800513
Date: 01/09/2019✓ County/FIPS: Catawba/035
Facility Data Permit Data
Hickory Springs Mfg. Co.dba HSM-Hickory Fabrication Permit 09079/R03
2377 Penny Road Issued 10/29/2015
Claremont,NC 28610 Expires 9/30/2023
Lat: 35d 42.0575m Long: 81d 9.4608m Class/Status Small
SIC: 3086/Plastics Foam Products Permit Status Active
NAICS: 32615/Urethane and Other Foam Product(except Polystyrene) Current Permit Application(s)None
Manufacturing
Program Applicability
Contact Data
SIP
Facility Contact Authorized Contact Technical Contact MACT Part 63: Subpart 60
Steve Hannah Scott Dahl Steve Hannah
Environmental Manager VP of Manufacturing Environmental Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 01/09/2019
Inspector's Name Donna Cook
Inspector's Signature: o a Cook Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: �� / On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2014 --- --- --- 6.65 --- --- ---
2009 --- ---
--- 8.03 --- --- ---
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

Hickory Springs Mfg. Co. dba HSM-Hickory Fabrication
January 9,2019
Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Tracking: X Date submitted for initial review 01/14/2019 ✓ _IBEAM WARNING/OB,NOD,NOV,NRE
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 01/01/2021
Directions: From Mooresville Regional Office to Claremont,travel Statesville Avenue;North Broad
Street and the name changes to Statesville Highway(Highway 115 North)and then to Charlotte Highway
(Highway 21 North and Highway 115 North);Interstate 77 North;Exit 5 1-Winston-Salem/Hickory to
Interstate 40 West toward Hickory; off Interstate 40 West take Exit 135-Claremont;turn left off exit ramp
onto N. Oxford Street; 0.7 mile turn right at stop light onto W. Main Street(Highway 70 West); 'h mile
turn left at stop light on Penny Road into the Claremont Industrial Park; and 0.7 mile on the right is the
facility. The street address of this facility is 2377 Penny Road.
SafetyEguipment: This company requires that safety glasses be worn by the inspector at this facility.
It is also recommended that safety shoes and ear protection be worn by the inspector at this facility. This
company has a sign-in sheet for visitors that contains a liability waiver. However, access to the facility
was granted to the inspector without having to sign the visitor's log.
Safety Issues: No safety issues were observed by me during the inspection.
Lat,EonQ: A review of the facility's coordinates on "Maps of DAQ Regulated Facilities" indicates the
facility's latitude and longitude coordinates are accurate. The facility name listed on the map is Carolina
Foam, LLC —Claremont instead of Hickory Springs, Mfg. Co. No changes to the latitude and longitude
coordinates of this facility in IBEAM are needed. Latitude and longitude coordinates of this facility are
locked in IBEAM.
Email Contacts: The email addresses for the authorized, facility, invoice and technical contacts were
verified by Mr. Steve Hannah, Environmental Manager. The email address of the authorized contact was
changed to Scott Dahl, vice president of manufacturing in IBEAM.
1. The purpose of this site visit was to conduct a routine air quality inspection. This company cuts
and glues flexible polyurethane foam for the upholstered furniture industry and sports equipment.
The operational hours of this company are 6 a.m. to 2:30 pm Monday through Thursday; 5 a.m.to
1:30 p.m. on Friday; and 9 p.m. to 5:30 a.m. Sunday through Thursday, 52 weeks per year. Mr.
Steve Hannah, environmental manager; Ms. Jane Roseman, plant manager; Ms. Zenaida
Camacho, environmental heath and safety specialist; and Mr. Robert Allen, maintenance
manager; accompanied me during this inspection. Mr. Hannah stated that 90% of this business is
upholstering chairs, sofas and love seats for the furniture industry; 5% for bedding and pillows;
and 5%for upholstering football tackling dummies and gymnastic equipment.

Hickory Springs Mfg. Co. dba HSM-Hickory Fabrication
January 9, 2019
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2. Facility Contact Information:
During the inspection, I verified the facility contact information in IBEAM with Mr. Hannah. I
changed the authorized contact in IBEAM to Mr. Scott Dahl,vice president of manufacturing.
3. Compliance history file review:
No problems have been noted in the last five years by DAQ prior to this inspection. The current
compliance status is discussed in the following sections.
4. Observations of permitted air emission sources and control devices:
Emission I Emission Source Control Control System
Source ID I Description j System ID Description
ES-F-01 (NESHAP) !flexible polyurethane foam N/A j N/A
gluing operation
The flexible polyurethane foam bun stock is~cut into desired shapes and sizes. This company spray
applies water-based synthetic latex adhesive (product,Fabond 1226UV; manufacturer, Worthen)
and a solvent-based adhesive(product,UN1133; manufacturer,Worthen)containing acetone and
heptane to the foam: Copies of the safety data sheets on these two glues are located in the file of
this facility. The spray lines and guns are cleaned with isopropanol (rubbing alcohol)for the
solvent-based adhesive and water for the water-based adhesive.
The foam adhesive spraying is being conducted on eleven tables that are covered in paper. This
company uses three tables for the water-based adhesive and eight tables for the solvent-based
adhesive.
None of the tables have any direct ventilation system. Instead, ductwork with four intakes runs
along the bottom portion of a wall adjacent to eight tables and then exhaust any gluing emissions
through two horizontal stacks to the outdoor atmosphere. The two horizontal and uncapped stacks
are located on the side of the building near the parking lot. One table is not connected to any
ductwork. The other two tables for the water-based adhesive has ductwork along the bottom
portion and then exhaust any gluing emissions through a single stack to the outdoor atmosphere.
The horizontal and uncapped stack is located on the side of the building near the parking lot.
A spray adhesive(product, Castle Trim Stick; product code, C2006; and manufacturer, Castle
Products,Inc.) in an aerosol spray can (18 %2 fluid oz or 389 g) is used to touch up the foam if the
product is torn. A copy of the safety data sheet is located in the file of this facility.
Observed. The employees were spray applying water-based and solvent-based adhesives to the
foam on three of the eleven tables during the inspection. I observed no visible emissions from the
adhesive spraying operations inside this facility or from the exhausts of the three stacks outside of
this facility. No spraying of adhesive from aerosol cans were observed by me during the inspection.

Hickory Springs Mfg. Co. dba HSM-Hickory Fabrication
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5. Observations of insignificant air emission sources and control devices listed on the current permit:
Source Exemption Source of Source of Title V
Regulation TAPs? Pollutants?
rS-1 -foam cutting 2Q .0102No No
eration
The flexible polyurethane foam bun stock cutting operations are conducted using various machines
such as a band saw, CNC (two horizontal and one vertical) and handheld cutters throughout this
facility. The large foam blocks (110 inch) are placed on platforms that moves the foam blocks
through horizontal saw blades approximately five feet in length that cuts the foam to desired
thickness. Another machine has a vertical saw blade that cuts the foam to desired widths and
shapes. Various handheld cutters are used to cut the foam to make seats, chair backs and other
products. The foam cutting machines do not exhaust to the outdoor atmosphere and are exempt per
2Q .0102 (g)(14)(J).
No adhesives are used in the foam cutting operations. This company uses two lubricant products
!(aerosol spray can 12.25 fluid oz., Big 5; product code C2004 for hinge lubrication; manufacturer,
Castle Products, Inc.; and silicone-based product E60 350,mixed with water and manufacturer,
Wacker Chemical Corporation; applied by spray bottles) on the blades of the handheld cutters and
horizontal and vertical cutting machines to keep the foam from sticking. The copies of the safety
data sheets are in the file of this facility.
Observed. The flexible polyurethane foam cutting operations were being conducted by various
machines during the inspection. None of the foam cutting machines exhaust to the outdoor
atmosphere. I observed no visible emissions from the flexible polyurethane foam cutting machines
inside of this facility.
6. Observations of air emission sources and control devices not listed on the current permit:
a. None noted.
7. Compliance with specific permit conditions and limitations:
a. Condition A. 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 with AA application form and submit the air pollution emission inventory report
with certification sheet for 2022 calendar year to MRO DAQ.
Observed. I informed Mr. Hannah that the current air permit will expire on September
30, 2023. Compliance with this stipulation is indicated.
b. Condition A. 3. Particulate Control Requirement-As required by 15A NCAC 2D .0515
"Particulates from Miscellaneous Industrial Processes," particulate matter emissions from
The emission sources shall not exceed allowable emission rates.
Observed. No particulate matter emissions are expected from the gluing operation as
indicated in the permit review. The foam cutting operations do not exhaust to the outdoor

Hickory Springs Mfg. Co. dba HSM-Hickory Fabrication
January 9, 2019
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atmosphere. Compliance with this stipulation was indicated during the permit application
process.
C. Condition A. 4. Visible Emissions Control Requirement-As required by 15A NCAC 2D
.0521 "Control of Visible Emissions",visible emissions from the emission sources,
manufactured after July 1, 1971, shall not be more than 20 percent opacity when
averaged over a six-minute period.
Observed. No visible emissions were observed by me from this facility. Compliance
with this stipulation is indicated.
d. Condition A. 5.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 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.
Observed. Based on a conversation with Mr. Hannah,no excess emissions have
occurred at the facility. Compliance with this stipulation is indicated.
e. Condition A. 6. Fugitive Dust Control Requirement as required by 15A NCAC 2D .0540
"Particulates from Fugitive Dust Emissions Sources" states that 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).
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.
f. Condition A. 7. 15A NCAC 2D .0958: Work Practices For Sources of Volatile Organic
Compounds - As required by 15A NCAC 2D .0958(c), the permittee shall store all VOC-
containing material in closed containers when not in use, store wipe rags in closed
containers, clean spills and equipment properly. As required by 15A NCAC 2D .0958(d),
when cleaning parts with a solvent containing a VOC, the permittee shall: flush parts in
the freeboard area, take precautions to reduce the pooling of solvent on and in the parts,
tilt or rotate parts to drain solvent and allow a minimum of 15 seconds for drying or until
all dripping has stopped, whichever is longer, not fill cleaning machines above the fill
line, and not agitate solvent to the point of causing splashing.
Observed. The adhesive containers were properly closed with tightly fitting lids and no
defects found in the containers or lids. No cleaning of any spraying equipment was being
conducted at this facility. No parts are being cleaned by this facility. 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.

Hickory Springs Mfg. Co. dba HSM-Hickory Fabrication .
January 9, 2019
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This condition no longer applies to this facility due to a rule change of 15A NCAC 2D
.0902(f) as amended on November 1,2016. This facility is not located in one of the
counties subject to this rule. Therefore,the requirements for 15A NCAC 2D .0958 will
not be applicable to any facility located in Catawba County. This condition will be
removed from the permit during the next revision.
g. Condition A. 8. Generally Available Control Technology(GACT)—For the flexible
polyurethane foam fabrication operations, polyurethane foam gluing operation(ID No.
ES-F-01),the permittee shall comply with all applicable provisions of 40 CFR 63,
Subpart 000000 "National Emission Standards for Hazardous Air Pollutants for
Flexible Polyurethane Foam Production and Fabrication Area Sources", including
Subpart A "General Provisions."
i. Standards and Compliance-Pursuant to 40 CFR 63.11416, the following
standards shall apply:
A. The permittee shall not use any adhesive containing methylene chloride
in a flexible polyurethane foam fabrication process.
ii. Recordkeeping Requirements-Pursuant to 40 CFR 63.11417,the following
recordkeeping requirements shall apply:
A. 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.
B. 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.
C. 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.
D. The permittee shall make the records-available for inspection upon
request of DAQ personnel.
Observed. According to the material data sheets provided by this company,the foam
water-based and solvent-based spray adhesives used by this facility do not contain any
methylene chloride. The foam water-based spray adhesive(product,Fabond 1226UV;
manufacturer,Worthen)contains synthetic latex. The foam solvent-based spray adhesive
(product,UN1133; manufactured by Worthen) contains acetone and heptane. The copies
of the material data sheets for the two foam adhesives are in the file of this facility.
This company does have various machines that are used to cut the foam into various
shapes and sizes. No adhesives are used in the cutting processes. A silicone based
lubricant product(product,E60 350;manufacturer, Wacker Chemical Corporation)
mixed with water is used to keep the blades of the cutting machines from sticking to the
foam. Compliance with this stipulation is indicated.

Hickory Springs Mfg. Co. dba HSM-Hickory Fabrication
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8. NSPS/NESHAP Review:
This facility has no NSPS affected sources.
The existing facility is subject to Subpart 000000 (60)-National Emission Standards for
Hazardous Air Pollutants for Flexible Polyurethane Foam Production and Fabrication Area
Sources (40 CFR 63.11414-11420) or referred to as GACT Subpart 000000 (60)for area
sources since adhesives (glues)are sprayed onto the foam. The NESHAP Subpart 60 rule
prohibits the use of any adhesive containing methylene chloride (MeCI) in the flexible
polyurethane foam fabrication process. This facility is complying with the requirements of
NESHAP Subpart 60 by not using any adhesives (glues)that contain methylene chloride.
This company does not have any engines/generators, fire pump engines, boilers or gasoline
storage tanks at this facility.
9. Summary of changes needed to the current permit:
a. Specific Condition and Limitation A. 7. 15A NCAC 2D .0958: Work Practices for
Sources of Volatile Organic Compounds should be removed from the permit during the
next revision. The 2D .0958 requirements do not apply to this facility, since it is located
in Catawba County.
b. The electronic yellowsheet 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.
DLC:Ihe
c: MRO File
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