AQ_F_0200089_20220722_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Royale Comfort Seating, Inc.-Plant No. 1
NC Facility ID 0200089
Inspection Report County/FIPS:Alexander/003
Date: 07/20/2022
Facility Data Permit Data
Royale Comfort Seating,Inc.-Plant No. 1 Permit 08939/T04
141 Alspaugh Dam Road Issued 7/10/2018
Taylorsville,NC 28681 Expires 6/30/2023
Lat: 35d 52.2612m Long: 8ld 11.5368m Class/Status Title V
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/Title V
Lee Isenhour Clyde Goble Lee Isenhour
HR and Safety President HR and Safety
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 07/20/2022
Inspector's Name Joe Foutz
Operating Status Operating
Inspector's Signature: JoV.P4A. E FOV z 09M Compliance Status Compliance-inspection
Action Code FCE
Inspection Result Violation
Date of Signature: 07/22/2022
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2021 --- --- --- 14.76 --- --- 29517.98
2020 --- --- --- 17.53 --- --- 35057.44
2019 --- --- --- 9.52 --- --- 17743.00
*Highest HAP Emitted in ounds
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
03/25/2022 NOV/NRE Permit Permit Condition 04/04/2022
02/16/2022 NOV Permit Late Report(excluding ACC) 02/28/2022
07/21/2021 NOV 2D.0521 Control of Visible Emissions 07/30/2021
09/24/2020 NOV/NRE Permit Late Report(excluding ACC) 10/05/2020
03/12/2019 NOV Permit Late Title V ACC 03/18/2019

Royale Comfort Seating,Inc. -Plant No. 1
July 20,2022
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Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
Type X Full Compliance —Partial Compliance _Complaint Other:
Action: Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 07/22/2022 X IBEAM WARNING/OB,NOD,NOV,or 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 07/01/2023
Directions: From MRO,travel 1-77 north to I-40 west. Take Hwy. 16 exit and travel north for
approximately 12 miles. Turn left onto Alspaugh Dam Road. The facility is located on the right at 141
Alspaugh Dam Road.
Safety Equipment: Safety glasses are recommended.
Safety Issues: None noted.
Lat/Lon2 Coordinates: A review of the facility's coordinates on"Maps of DAQ Regulated Facilities"
indicates the facility's latitude and longitude coordinates are accurate and locked in IBeam.
Email contacts: No changes were needed at this time.
l. General Information: The purpose of this site visit was to conduct a routine air quality inspection.I
arrived at the facility around 10:30 am on July 20, 2022. This facility cuts and glues foam for
furniture cushions. The facility is currently operating forty hours per week.Mr.Bradley Looper,Plant
Manager, accompanied me during this inspection.
'2. File Review.
A. Contacts. During the inspection,I verified that the facility contact information in IBEAM was
correct. No changes are needed.
B. Files. The following files were reviewed prior to the inspection: current permit,previous
inspection reports, quarterly, semiannual, and annual reports, and annual emissions inventories.
C. Compliance history:
A Notice of Violation with Recommendation for Enforcement(NOV/NRE)was issued on
November 21,2014 for operations exceeding the HAP 10 tons per 12-month period Title V
threshold level with trichloroethylene.

Royale Comfort Seating, Inc.-Plant No. 1
July 20,2022
Page 3
A Notice of Deficiency(NOD)was issued on March 17, 2016 for a late annual report of VOCs
and HAPs. The report was received March 28, 2016.
A Notice of Violation(NOV)was issued on March 6,2017 for late submission of the VOC and
HAP emissions report.
An NOV was issued on March 12,2019 for late submission of their annual compliance
certification(ACC).
An NOV/NRE was issued on September 24, 2020 for late submission of the semiannual VOC and
visible emission reports.
An NOV was issued on July 21, 2021 for failure to conduct monthly visible emission
observations.
An NOV was issued on February 16,2022 for a late semi-annual report of VOC emissions and
monitoring activities.
An NOV/NRE was issued on March 25,2022 for a submitting an inaccurate ACC.
D. NSPS/NESHAP Review
The facility is not subject to NESHAP 4Z because there are no generators at the facility.
The facility is not subject to NESHAP 6J because there are no boilers at the facility.
The facility is not subject to NESHAP 6C because the facility does not have any gasoline storage
tanks.
The facility is not subject to NESHAP 60 because the facility is a major source for HAPs.
According to the Air Permit Application review conducted for Air Permit 08939R04 on July 10,
2018,the facility is not subject to:
- NESHAP 3I(Flexible Polyurethane Foam Production) because the facility is not
engaged in foam production.
- NESHAP 5M(Flexible Polyurethane Foam Fabrication Operations)because the
facility does not operate a flame lamination source or loop slitter affected source.
3. Part I-AIR QUALITY TITLE V OPERATION PERMIT. The following permitted emission sources
and/or control devices listed in Section 2 Paragraph 2.1-Emission Source(s) and Control Devices(s)
Specific Limitations and Conditions were observed during this inspection:
Emission Source ' Control Device Control Device
ID No. Emission Source Description ID No. Description
ES-2 Foam Fabrication Process consisting N/A N/A
of Glue Spraying Operation
Observed.The facility has two buildings and each building has glue spray booths.The facility glues
together foam pieces but does not make any foam. Mr.Looper stated the second building was
constructed and started operating in May 2022.

Royale Comfort Seating,Inc. -Plant No. 1
July 20,2022
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Building 1 (the original building)has 6 spray booths with 2 spray stations on each side of the booth,
for a total of 12 glue spray stations. Each spray booth is vented to atmosphere for a total of 6
exhausts. Each exhaust exits the side of the building and is a horizontal exhaust. The facility had 2
additional spray booths in this building that have been removed but the ductwork remains.
Building 2(the newer building)has 4 spray booths with 2 spray stations on each side of the booth,for
a total of 8 glue spray stations. A total of 4 vents exhaust to atmosphere, one exhaust for each spray
booth. Each exhaust exits through the side of the building and is a horizontal exhaust. Mr.Looper
stated the glue spray booths started operating in May 2022.
There is one tote containing glue in each building and glue is pumped from the tote to each spray
station. Each tote contains 345 gallons of glue.
During the inspection, 5 spray stations were operating in Building 1 and 3 stations were operating in
Building 2. 1 observed no visible emissions and did not detect any odors.
1. 15A NCAC 2D .0515: Particulates from Miscellaneous Industrial Processes
Emissions of particulate matter from this source(ID No.ES-2) shall not exceed an allowable
emission rate.
a. The Permittee shall maintain production records such that the process rates "P" in tons per
hour, as specified by the formulas contained above can be derived and shall make these
records available to a DAQ authorized representative upon request. The Permittee shall be
deemed in noncompliance with 15A NCAC 02D .0515 if the production records are not
maintained or the types of materials and finishes are not monitored.
b. No reporting is required for particulate emissions from this source(ID No. ES-2).
Observed. The facility keeps records of the amount of glue used in Building 1 only. I
informed Mr. Looper the facility is also required to track glue usage in Building 2. The
facility used approximately 3,465 gallons of glue in 2021, and 1,725 gallons through June
2022.According to the SDS for the glue(product code 55388), each gallon weighs 10.33 lbs
and contains very little particulate. Each tote contains 345 gallons of glue and the glue is up
to 75%TCE. It appears the facility is well under the allowable emission rate.Compliance is
indicated.
2. 15A NCAC 2D .0521: Control of Visible Emissions
Visible emissions from this source(ID No.ES-2) shall not be more than 20 percent opacity when
averaged over a six-minute period.
a. To ensure compliance, once a month the Permittee shall observe the emission points of this
source(ID No.ES-2)for any visible emissions above normal. The monthly observation must
be made for each month of the calendar year period to ensure compliance with this
requirement. The results of the monitoring shall be maintained in a logbook(written or
electronic format)on-site and made available to an authorized representative upon request.

Royale Comfort Seating,Inc. -Plant No. 1
July 20,2022
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b. The Permittee shall submit a summary report of the monitoring and recordkeeping activities
given in the permit, postmarked on or before January 30 of each calendar year for the
preceding six-month period between July and December and July 30 of each calendar year
for the preceding six-month period between January and June.
Observed. During the inspection, 5 glue spray stations were operating in Building I and 3
glue spray stations were operating in Building 2. 1 observed no visible emissions. The
facility keeps a logbook with visible emission observations for the spray booths in Building 1
only. There are no records for the glue spray booth exhausts in Building 2. 1 informed Mr.
Looper that visible emission readings should also be conducted on the spray booth exhausts
from Building 2. The facility is in compliance with conducting visible emission observations
from the spray booth exhausts in Building 1. However,the facility has not been conducting
visible emission observations from the spray booth exhausts in Building 2 since they started
operating in May 2022.
3. 15A NCAC 02D .1806: Control and Prohibition of Odorous Emissions
The Permittee shall not operate the facility without implementing management 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.
Observed. I did not experience any odors off property and this office has not received any odor
complaints since the last inspection. Compliance was indicated.
4. 15A NCAC 02Q .0317 PSD Avoidance for 15A NCAC 02D .0530: Prevention of Significant
Deterioration
To avoid applicability of 15A NCAC 02D .0530: Prevention of Significant Deterioration,the
VOC emissions from this source(ID No. ES-1) shall be less than 250 tons per consecutive 12-
month period. (NOTE: the air permit states"this source(ID No. ES-1)"; however,the source ID
No. should be ES-2. This change was noted on the yellowsheet)
a. Calculations of VOC emissions per month shall be made at the end of each month. VOC
emissions shall be determined by multiplying the total amount of each type of VOC-
containing material consumed during the month by the VOC content of the material.
b. Calculations and the total amount of VOC emissions shall be recorded monthly in a logbook
(written or electronic format).
c. The Permittee shall submit a semi-annual summary report of monitoring and recordkeeping
activities given in the permit, postmarked on or before January 30 of each calendar year for
the preceding six-month period between July and December,and July 30 of each calendar
year for the preceding six-month period between January and June. The report shall contain
the monthly VOC emissions for the previous 17 months. The emissions must be calculated
for each of the 12-month periods over the previous 17 months.
Observed. Records of VOC emission calculations are being kept for glue usage in Building
1. I observed the monthly VOC calculations based on material used through May 2022. The
most recent report was received on July 18,2022 but does not contain information or
emissions from the glue spray booths in Building 2,which started operating in May 2022.I

Royale Comfort Seating,-Inc. -Plant No. 1
July 20, 2022
Page 6
explained to Mr. Looper that emissions from the additional glue spray booths need to be
included in their monthly VOC calculations. Subsequent to the inspection,I emailed Mr.
Looper an example on how to track monthly emissions on an excel spreadsheet. The facility
is in compliance with tracking VOC emissions from Building 1. I informed Mr.Looper that
he needed to include VOC emissions from Building 2 in his calculations.
4. Part II-AIR QUALITY TITLE V OPERATION PERMIT. Section 3 - GENERAL CONDITIONS
A. Permit. Maintain a copy of the permit and application at the facility.
Observed. The permit and application are kept at the facility.
B. Submissions. Except as otherwise specified,two copies of all documents, reports,test data,
monitoring data are required to be submitted to MRO.
Observed. The company has been complying with this requirement.
C. Circumvention. Operate and maintain the facility at all times in a manner that will affect an
overall reduction in air pollution.
Observed. The facility appears to comply with this requirement.
D. Permit Modification. Minor Permit Modifications. The Permittee shall submit an application for
a minor permit modification in accordance with 15A NCAC 02Q. 0515.
Observed. The permittee installed and is currently operating 2 new spray booths without
.modifying their permit and without applying for a 502(b)(10)notification. As a result, DAQ-
MRO will issue an NOV to Royale Comfort Seating,Inc.—Plant No. 1 for operating emissions
sources without a permit.
E. Excess Emissions. Report excess emissions and permit deviations as required.
Observed. No excess emissions have occurred. Compliance is indicated.
F. Retention of Records. The Permittee shall retain records of all required monitoring data and
supporting information for a period of at least five years from the date of the monitoring sample,
measurement,report, or application.
Observed. Records are being maintained.
G. Compliance Certification.By March 1 submit a compliance certification(for the preceding
calendar year).
Observed. The facility indicated that they sent the ACC on February 28,2022 but failed to
provide adequate information. An NOWNRE was issued on March 25, 2022 for failure to submit
a complete ACC.
H. Emissions Inventory. Submit an emissions inventory by June 30 of each year.
Observed. The facility submitted their 2021 emission inventory on February 17,2022.
1. Refrigerant Requirements(Stratospheric Ozone and Climate Protection). Dispose of refrigerants
properly.
Observed. The facility uses a certified outside contractor for maintenance on refrigeration
equipment.
J. Section 112(r). 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.

Royale Comfort Seating,Inc. -Plant No. 1
July 20, 2022
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5. The following non-permitted air emission sources and control devices were observed as follows:
None.
6. Summary of changes needed to the current permit:
Permit Condition 2.1.A.4.a. references emission source ID No. ES-1. This should be changed to ES-2
since ID No.ES-2 this is-the only source identified in the air permit. This change has been noted on
the yellowsheet.
7. Compliance assistance offered duringthe he inspection:
I informed Mr. Looper that the addition of glue spray booths in the newly constructed building
without modifying the air permit was a concern. Subsequent to my inspection,I called Mr. Looper
and left him a voicemail indicating DAQ-MRO will be issuing an NOV to the facility for installing
emission sources without modifying the air permit.
Subsequent to the inspection,I provided Mr.Looper with some sample calculations and an
explanation on how to improve the semi-annual reports and VOC calculations.
I reminded Mr. Looper the air permit expires June 23,2023 and an air permit renewal application
needs to be submitted at least 6 months prior to the expiration date.
8. Compliance determination:
Based on my observations,this facility is in violation because of the construction and operation of
additional glue spray booths without modifying the air permit.
JEF:
MRO File
https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00089/INSPECT_20220720.docx