AQ_F_1800011_20220908_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Bassett Upholstery Division
NC Facility ID 1800011
Inspection Report County/FIPS:Catawba/035
Date: 08/23/2022
Facility Data Permit Data
Bassett Upholstery Division Permit 03981 /RI
1111 East 20th Street Issued 8/10/2016
Newton,NC 28658 Expires 7/31/2024
Lat:35d 40.9510m Long: 81d 12.3960m Class/Status Synthetic Minor
SIC: 2512/Upholstered Household Furniture Permit Status Active
NAICS: 337121 /Upholstered Household Furniture Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Theodore Lewis Mike Kreidler Theodore Lewis MALT Part 63: Subpart 6J,Subpart 60
Maintenance Supervisor VP of Upholstery Maintenance Supervisor NSPS: Subpart De
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 08/23/2022
Inspector's Name Joe Foutz
Operating Status Operating
Inspector's Signature: FOIA4Z 019M Compliance Status Compliance-inspection
Action Code FCE
Inspection Result Violation
Date of Signature: 09/08/2022
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2015 3.75 0.2200 4.11 44.08 4.98 2.82 9537.60
2010 5.27 2.97 4.54 24.14 4.47 2.17 5727.68
*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

Bassett Upholstery Division
August 23, 2022
Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review: 9/09/2022 X IBEAM WARNING/OB,NOD,NOV,NRE
Tracking: X IBEAM Document
X IBEAM Inspection,list date inspected X IBEAM LAULONG,Facility Locked
X IBEAM Inspection, list date draft is submitted X IBEAM L,AT/LONG,Coordinates checked
X IBEAM Inspection,pollutants/programs checked _IBEAM Complaint
X IBEAM Next Inspection Date: 8/01/2023
Directions: From MRO,take Hwy. 150 West,turn right onto Hwy. 16 North through Newton,turn right onto College
Rd. (turns into Main St.). Turn right onto 20"' Street. The Facility is located on the right at Burris Road.
Safety guipment: Safety glasses and safety shoes are recommended.
Safety Issues: When inspecting the spray booths,beware of moving parts on overhead conveyor system.
Lat/Long Coordinates: A review of the facility's coordinates on"Maps of DAQ Regulated Facilities"indicated
the facility's latitude and longitude coordinates were accurate and locked within IBEAM.
Email Addresses: The email addresses for the contacts in IBEAM were verified, and no changes are required.
1. The purpose of this site visit was to conduct a routine air quality inspection. This facility manufactures
upholstered furniture. The facility operates two router teams, six days a week and 12 hours per day. The
assembly portion of the plant works 8 hrs per day and 5 days per week. The plant shuts down for the week of the
4"of July holiday and for 2 days during Christmas. I arrived at the facility at about 10:15 AM on August 23,
2022.Mr. Theodore(Ted)Lewis,Assistant Maintenance supervisor, accompanied me during this inspection.
2. Facility Contact Information:
During the inspection, I verified the facility contact information in.IBEAM. The Invoice Contact has changed to
Theodore(Ted)Lewis, Maintenance Manager. I notified Sandy Sherer of the changed needed in IBeam. No
other changes are needed at this time.
3. Compliance history file review:
An NOV/NRE was issued to the facility on April 14,2013 for failed stack test conducted on December 12,2012.
The facility was assessed $2,265,which was paid in full on June 24, 2013. The facility re-tested on November
12, 2013 and demonstrated compliance.
An NOD was issued to the facility on February 10,2022 for submitting a late annual report.

Bassett Upholstery Division
August 23, 2022
Page 3
4. Observations of permitted air emission sources and control devices:
Emission =Emission Source Control Control System
Source ID Description System ID Description
.Furniture Finishing Operation(ID No.F-1)
1ES-SB-5, �five(5)dry filter-type paint
ES-SB-6, spray booths
EES-SB-7, N/A N/A
ES-SB-8,
ES-SB-9
;Observed. Three spray booths were operating during the inspection. There were no visible emissions.Note
,that the facility has a total of 9 dry filter-type spray booths because the baffle filter spray booths listed below
(ES-SB-1 through ES-SB-4) have been converted to dry filter spray booths. Mr. Lewis stated that the filters
Are changed weekly or as needed. Some of the spray booths are very large and can accommodate multiple
!spray guns.
m Emission Emission Source Control Control System
Source ID Description System ID escription
ES-SB-I, Your(4) baffle filter-type
ES-SB-2, ;paint spray booths N/A N/A
ES-SB-3,
DES-SB-4
Observed. The baffle filter-type spray booths have been converted to dry filter. As noted above,the
facility has a total of 9 dry filter-type spray booths.
Emission Emission Source v Control Control System
ource IDDescription� "System ID Description
- - - --
ES-T-1 wash-off tank N/A N/A
I -----
Observed. The wash-off tank was not in use during the inspection and was covered with a lid.
__.
iEmission �� EmiSSlon Source - Control ,Control System . i
source'ID' (Description ; System,ID'' Description
ES-LD-I furniture leg dipping fN/A N/A
(operation ?
_— _-------------
operation is not being used by the facility at this time.
'Emission Emission Source Control I ? Control System
'Source ID. }Description System ID } Description
-G-1 (N_ES HAP) (gluing operations N/A ) N/A
Observed. The facility has various gluing operations throughout the facility. The facility uses the glue
during assembly of wooden frames. The facility does not glue any foam.

Bassett Upholstery Division
August 23,2022
Page 4
Emission m- 'Emission Source Control Control System _
Source,ID; Description ;System ID I Description
woodworking Operations
ES-W-I woodworking CD-C-3,~ _ ;cyclone(CD-C-3,80 inches in diameter)
operation#1 CD-F-I, 'installed in parallel with a
CD-F-4, Ebagfilter(CD-F-2,3,873 ft2 of filter area)that
CD-F-2 is installed in parallel with two other bagfrlters
!(ID No. CD-F-1; 1,340 ft2 of filter area)and
(ID No. CD-F-4; 1,155 ft2 of filter area)
Observed. This woodworking operation is housed in building#2 and consists of a wood hog(grinder)and
routers. A more detailed description of the sources and control devices is discussed in the next few
paragraphs but in general,wood waste captured from these sources is either sent to a silo for storage or to a
trailer for transport off-site. Wood waste captured and sent to the silo will eventually be used as fuel for the
wood-fired boiler(ES-B-2). However, if the facility has adequate wood fuel for the boiler,then the wood
waste is sent via ductwork to an enclosed trailer that is hauled off--site. Mr. Lewis stated there is a lever that
can be switched to direct the wood waste flow to the silo or the trailer.
Below is a more detailed description of the control device system operation.
E
f
The cyclone(CD-C-3)is used in series with the Pneumafil bagfilter(CD-F-2) to control wood waste from
the wood hog(grinder). Wood waste from the grinder is sent to the cyclone(CD-C-3)that sits on top of the
wood storage silo(I-SILO). Wood waste captured by the cyclone is sent to the trailer or wood storage silo.
The exhaust from the cyclone(CD-C-3) is sent to the bagfilter(CD-F-2). The exhaust from the bagfilter is
vented to atmosphere near the roof's surface. Wood waste captured by the bagfilter is sent via ductwork to a
separate unnamed/unidentified cyclone(96 inch diameter)that sits on top of the wood silo.
((Another set of woodworking equipment(panel saw and some routers)vent their emissions to the Carter Day i
(bagfilter(CD-F-4)and exhausts to atmosphere at the roof's surface. Wood waste captured by the bagfilter 1
(CD-F-4)is sent via ductwork to the unnamed/unidentified cyclone(96 inch diameter). Wood waste
captured by the cyclone is sent to the trailer or the wood silo(I-SILO). Exhaust from the cyclone(96 inch
diameter) is sent back to the bagfilter(CD-F-4).
Another set of workworking equipment(saws and routers)vent their emissions to the Pneumafil bagfilter
(CD-F-2)and exhaust to atmosphere at the roof's surface. Wood waste captured by the bagfilter is sent via
ductwork to the unnamed/unidentified cyclone(96 inch diameter)that sits on top of the wood silo(I-SILO). I
Wood waste captured by the cyclone is sent to the wood silo or trailer. Exhaust from the cyclone is sent
back to the bagfilter(CD-F-2).
The bagfilter(CD-F-1) is not being used and is disconnected.
I observed the woodworking in operation with no visible emissions from the control devices. However,
captured wood waste was being sent to the enclosed trailer where I observed wood waste venting/escaping
from the back of the trailer. Mr. Lewis stated the trailer currently under the canopy/enclosure is shorter than
the typical trailer. As a result, some wood waste was escaping the end of the trailer.

Bassett Upholstery Division
August 23, 2022
Page 5
Emission - lEmission Source ; Control. Control System
,Source ID (Description System ID ; Description
�ES-W-5 oodworking operation#5 CD-C-I simple cyclone(156 inches in diameter)
Observed. Woodworking operation#5 has been taken out of service.
Emissiony ,Emission Source Control Control System
Source JD bescription System ID Description'
ES-W-6 Sample production area CD-C-2 simple cyclone(60 inches in diameter) 1
.Observed. This woodworking operation is housed in building#1 and is considered the R&D area. There is a I
router,planer and some saws in this area. The process was in operation with no visible emissions.
3
�[� Control System -lEmission ;Emission Source Control
Source ID GDescription System ID j Description
ES-B-2coal/wood fuel-fired boiler(36 CD-2 (multi-cyclone
(NESHAP) mmBtu/hr max heat input) 1(18 nine-inch diameter tubes)
:Observed. The boiler was not operating at the time of the inspection. Mr. Lewis stated coal has not been
;used in the boiler for many years and wood is the only fuel that is being used. Mr. Lewis stated the boiler is
'only used during the colder months. As a result,the facility generates more wood waste than they combust so
they provide their wood waste to another company.
Emission 14W4 ;Emission Source Control Control.System TA
source'ID ;Description System ID Description
ES-B-3 liatural gas/No. 2 fuel oil-fired boiler N/A N/A
(NSPS,NESHAP) (38.64 m III Btu/hr max. heat input).
IlObserved. The boiler was not operating at the time of inspection. Mr.Lewis stated the boiler only operates
during the colder months and if the wood fired boiler is not operating. Although the boiler is permitted to
!burn both natural gas and No. 2 fuel oil, Mr.Lewis stated boiler is not capable of combusting No.2 fuel oil.
;The boiler has never combusted fuel oil and,as a result,has no requirements under NSPS De. I informed Mr.
iLewis if fuel oil is combusted in the boiler,then the boiler must comply NSPS Subpart Dc.

Bassett Upholstery Division
August 23,2022
Page 6
5. Observations of insignificant air emission sources and control devices listed_on the current permit:
Sourcexemptton _T ! Source of T Source of Title V
Regulation j TAPs? I Pollutants?
I-ES-0-1 -natural gas-fired paint cure oven 2Q 0102 (h)(l)(B) Yes Yes
(1.5 mmBtu/hr max heat input rate)
Observed.Furniture that has been stained/painted is dried in the oven. The oven was in operation
with no visible emissions.
rES-O -na-2tural gas-fired shk w rinrap oven
(3.0 m mBtu/hr max. heat input rate)) 2Q .0102 (h)(1)(B) Yes Yes
Observed.Furniture is packed and wrapped in plastic and sent through the oven for shrink
wrapping. The oven was in operation with no visible emissions.
�fw-TANK 1 —diesel fuel storage tank 2Q .0102 (g)(4) No No
(1,000 gallons capacity)
IT01he
bserved. The tank is located outside Building#1 near the Sample Production Area(ES-W-6)
diesel fuel is only used for mobile equipment.
I-TANK2-waste oil storage tank `2Q .0102(g)(4) No No
(500 gallons capacity)
Observed. The tank was observed and no issues were noted.
I-TANK3 -gasoline storage tank 2Q .0102 (g)(4) No No
(500 gallons capacity)
Observed. This tank has been disconnected and is not in use at this time.
1I TANK4-fuel oil storage tank
(250 gallons capacity) 2Q .0102 (g)(4) No No
Observed. The tank was not observed during this inspection.
�(CD-17-3�,w5C4
ILO od storage silo with bin vent Yes
square feet of filter area) 2Q .0102 (h)(5) No E
Observed. The silo stores wood dust for use as fuel in the wood-fired boiler(ES-B-2). The facility
does not combust wood until the colder months and generate a surplus of wood dust. The surplus
wood dust bypasses the wood storage silo.(I-SILO)and is sent via ductwork to an enclosed trailer.
The trailer is hauled by another company and used. During the inspection,wood dust was being
sent to the trailer. Wood dust was visible escaping the back portion of the trailer.
6. Observations of air emission sources and control devices not listed on the current permit:
An enclosed trailer is used to collect wood dust from the woodworking operations when the wood dust is
not needed for the wood storage silo(I-SILO).
A cyclone, 96 inches in diameter, is located on top of the wood storage silo and sends wood dust to the
silo or the trailer.

Bassett Upholstery Division
August 23, 2022
Page 7
7. Compliance with specific permit_conditions and limitations:
a. Condition A.2. 15A NCAC 2D 0202, "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. The report shall be submitted to the Regional Supervisor, DAQ and shall document air
pollutants emitted for the 2023 calendar year.
Observed.The current permit expires 07/31/2024. I discussed the renewal process with Mr.Lewis.
Compliance is indicated.
b. Condition A.3. 15ANC'.AC 2D .0503 "Particulate from Fuel Burning Indirect Heat Exchangers" limits the
facility's coal/wood and natural gas/No. 2 fuel-fired boilers to allowable emissions rates as detailed in the
permit.
Observed. The boiler(lS-13-2) no longer combusts coal and only combusts wood. The boiler(ES-B-3) only
combusts natural gas and has not combusted any fuel oil since it began operation. Compliance is
demonstrated in the last_perm it review.
c. Condition A.4. 15A NCAC 2D .0504"Particulate from Wood Burning Indirect Heat Exchangers" limits the
facilities coal/wood is allowable emissions rates as detailed in the permit.
Observed. The boiler(lS-B-2)was not operating during the inspection and was undergoing maintenance
and cleaning. A stack test was conducted on 11/12/2013 and showed compliance. When operating,it is
anticipated the boiler will be in compliance with this condition.
d. Condition A.5. 15A NCAC 21) .0512 "Particulates from Wood Products Finishing Plants". Provide adequate
duct work and properly designed collectors to control woodworking particulates.
Observed. The facility appeared to have adequate duct work. The bagfilters and cyclones appeared to
provide sufficient control for their woodworking operations. The facility also has dry filters overlaying
baffles in the spray booths. Compliance is indicated.
e. Condition A.6. 15A NCAC 2D .0516, "Sulfur Dioxide Control Requirement". The permittee is required to
limit sulfur dioxide emissions from combusted fuel to 2.3 pounds per million Btu heat input.
Observed. This requirement was evaluated during the permit review process and the facility was found to be
in compliance.
f. Conditions A.7. and A.B. 15A NCAC 2D .0521, "Control of Visible Emissions". The facility is limited to 20
percent opacity for paint spray booths(ES-SB-7,ES-SB-8,ES-SB-9);boiler(ES-B-3); gluing operations(ES-
G-1); leg dipping operation (ES-LD-I);woodworking-operation(ES-W-1); and simple production area(ES-
W-6). The facility is limited to 40 percent opacity for paint spray booths(ES-SB-I through ES-SB-6); boiler
(I;S-13-2); wash-off tank(1?S-T-1); and woodworking operation(ES-W-5).
Observed. The facility appeared to be in compliance with this condition.

Bassett Upholstery Division
August 23, 2022
Page 8
However, during the inspection,wood dust was observed escaping/venting from the back of a trailer used to
haul the wood dust offsite.Mr.Lewis stated the wood dust was escaping because the trailer was shorter than
the canopy delivering wood dust to the trailer. Because of the trailer size,the canopy was not sealing properly
and allowing wood dust to escape. Therefore,the facility is in violation of Air Permit Condition B.6 and an
NOV will be issued to the facility.
g. Condition A.9. 15A NCAC 2D .0524 "New Source Performance Standards". The natural gas/No. 2 oil-fired
boiler(ID No. ES-B-3) is subject to NSPS Dc requirements. The facility is required to submit fuel type at the
time of start-up notification. The facility is required to test the boiler using the fuel reported to DAQ for
visible emissions. Subsequent to initial testing,the facility can perform periodic opacity monitoring or
develop a site-specific monitoring plan requiring DAQ approval. The facility needs to keep monthly records
of the fuel type combusted and quantities used. Records must be maintained for two years. The facility must
submit a semi-annual report after start-up of No. 2 fuel oil.
Observed. Mr. Lewis stated the natural gas/No.2 fuel oil fired-boiler(1S-13-3) boiler only combusts natural
gas. The boiler has not and cannot combust No. 2 fuel oil because there are no lines to supply fuel oil to the
boiler. Mr. Lewis also stated that the boiler is only used if the wood fired boiler(ES-B-2) is malfunctioning
or down for maintenance. I informed Mr. Lewis that a report is not required if the boiler never combusts fuel
oil. However, once fuel oil is combusted in the boiler then an NSPS Dc semi-annual report must be
submitted. Compliance is indicated.
h. Condition A.10. 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.
Observed. Based on a records review and conversations with Mr.Lewis,no excess emissions have occurred
at the facility since the last inspection. Compliance with this condition is indicated.
i. Condition A.11. 15A NCAC 2D .0540"Particulates from Fugitive Dust Emission Sources". The facility
must not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess
visible emissions beyond the property boundary.
Observed. There have not been any dust complaints received for this facility. Wood dust was observed
exiting the trailer that was receiving all the collected wood dust. However,the wood dust was not observed
leaving the property. Compliance is indicated.
j. Condition A.12. 15A NCAC 2D .0958: "Work Practices for Sources ol'Volatile Organic Compounds." Store
all VOC-containing material in closed containers when not in use,and clean spills and equipment properly.
Observed. No spills or source issues were observed. All containers were properly closed with lids on top.
Compliance with this stipulation is indicated.
k. Condition A.13. 40 CFR 63, Subpart 000000, "National Emission Standards for Hazardous Air Pollutants
for Flexible Polyurethane Foam Production and Fabrication Area Sources". The gluing operation(ES-G-1) is
subject to this Rule,which states that the facility cannot use any adhesive containing methylene chloride.
Observed. The facility no longer uses adhesives that contain methylene chloride. They keep MSDS on site
of the adhesives used. Compliance is demonstrated.

Bassett Upholstery Division
August 23, 2022
Page 9
1. Condition A.14. 40 CFR 63, Subpart JJJJJJ, "National Emission Standards for Hazardous Air Pollutants for
Area Sources: Industrial, Commercial, and Institutional Boilers".Both Boilers (ES-B-2 and ES-13-3)are
subject to this Rule.
Compliance Dates:
A tune-up and energy assessment is required no later than March 21,2014.
Compliance Requirements,:
A biennial tune-up is required to be conducted within 25 months after the previous tune-up. If the boiler is
seasonal then tune-up is required within 5 years(61 months). A boiler is defined as seasonal if it is
shutdown for 7 consecutive months or 210 consecutive days each 12-month period due to seasonal conditions.
The tune-up shall be conducted while combusting the type of fuel that provides the majority of the head input
to the boiler over the 12 months prior to the tune-up. The tune-up shall:
- inspect of the flame pattern and adjust the burner as necessary to optimize the flame pattern,
- inspect of the system controlling the air-to-fuel ratio and ensure that is correctly calibrated and
functioning properly.
- optimize total emissions of carbon monoxide.
- Measure the concentrations in the effluent stream of CO in ppm, by volume,and oxygen in volume
percent, before and after the adjustments are made.
Notification and Rep
orting-Rc uirements:
Submit an Initial Notification by January�20, 2014 and an NOCS by July 19,2014. The permittee must
prepare a comp]iance report by March 1 of every other year(or every 5 years depending on the
frequency of the tune-up requirements). The report shall be submitted to DAQ by March 15 if the
source experiences any deviations from the applicable requirements.
Recordkee in Requirements:
The permittee must maintain tune-up records including:
- concentrations of CO in the effluent stream before and after the tune-up.
- correction actions taken.
For each boiler that meets the definition of seasonal boiler,the permittee must:
- keep records of days of operation per year.
Records must be kept for 5 years following the date of each recorded action.
Observed. The facility conducted the initial boiler tune-ups on March 8,2012 and completed a combustion
analysis on October 23, 2012. The energy assessment was completed December 9, 2013. The NOCS was
submitted in CEDRI on July 14, 2014.
The facility previously conducted biennial tune-ups on the wood fuel-fired boiler(ES-B-2)on August
4,2017 and April 17, 2019. Previous inspections indicated the wood fuel-fired boiler(ES-B-2)could
be considered a seasonal boiler(shutdown for a period of at least 210 consecutive days each 12-
monthperiod due to seasonal conditions). A tune-up is required every 5 years for seasonal boilers.
However,Mr. Lewis could not provide records showing the days the boiler(ES-B-2)has operated. In
addition, the facility's annual report shows wood was combusted in the boiler every month in
calendar year 2021. As a result, the wood fuel-fired boiler(ES-B-2) cannot be considered a seasonal
boiler and the tune-up is required biennially.

Bassett Upholstery Division
August 23,2022
Page 10
The facility previously conducted a tune-up on the natural gas/fuel oil Fired boiler(ES-B-3)on April
17,2019. During previous inspections,the permittee was able to provide records showing the boiler
(ES-B-3)can be considered a limited use. However, limited use as defined in NESHAP 6J
(63.11237)states, "any boiler that burns any amount of solid or liquid fuels and has a federally
enforceable annual capacity factor of no more than 10 percent". The current air permit for this
facility does not contain any limit on the natural gas/fuel oil fired boiler (l;S-B-3). As a result,the
boiler cannot be considered limited use.
Since the facility could not provide records showing the days the wood fuel-fired boiler(ES-B-2)has
operated and the facility's annual report shows the boiler combusted wood each month in 2021 then a tune-up
should have been conducted within 25 months from the previous nine-up or no later than May 17,2021.
Also, since the natural gas/No. 2 fuel oil-fire boiler(ES-B-3)does not have a federally enforceable annual
capacity then it cannot be considered limited use as defined by NESI=IAP 6J. As a result,a tune-up on the
boiler(ES-B-3) should have been conducted within 25 months from the previous tune-up or no later than May
17,2021.
Since the facility has not conducted a tune-up on the boilers by the required timefiame,then an NOV will be
issued to the permittee for violation of NESHAP 6J.
in. Condition A.15. 15A NCAC 2Q .0501 "Synthetic Minor Facilities." Facility-wide emissions shall be less
than the following:
Emission Limit _
Pollutant F
(Tons per consecutive 12-montli period)'
PM10 100
j S02 _100_
NOx 100
VOC 100
CO 100
Individual HAPs; 10
Total HAPs 1 25
Operations Restriction: To ensure that the facility-wide emissions do not exceed the permit limits:
- The sulfur content of the coal combusted in the boiler(ES-13-3)shall be limited to 1.0%sulfur by
weight.
Inspections and Maintenance Requirements:
- Bagfilter Requirements—Particulate matter emissions shall be controlled as described in the
permitted equipment list. The Permittee shall perform periodic inspections and maintenance
as recommended by the manufacturer.In addition,the Permittee shall perform an annual(for
each 12-month period following the initial inspection) internal inspection of each bagfilter
system.
- Cyclone Requirements-Particulate matter emissions shall be controlled as described in the
permitted equipment list. The Permittee shall perform an annual (for each 12-month period
following the initial inspection) inspection of the cyclone system.in addition,the Permittee
shall perform periodic inspections and maintenance as recommended by the manufacturer.

Bassett Upholstery Division
August 23, 2022
Page 11
Multi-Cyclone Requirements -Particulate matter emissions shall be controlled as described in
the permitted equipment list. The Permittee shall perform an annual(for each 12-month
period following the initial inspection) internal inspection of the multi-cyclone system. In
addition, the Permittee shall perform periodic inspections and maintenance(I&M)as
recommended by the manufacturer.
Recordkeeping Requirements:
The Permittee shall record monthly and total annually:
- The type and amount of fuel combusted in the boilers(ES-13-2 and ES-13-3)
The facility-wide sulfur dioxide, nitrogen oxides, carbon monoxide,VOC, highest individual
HAP, and total I lAP emissions.
- Fuel supplier certification shall be kept on-site and make available to DAQ upon request.
- A log book shall be kept onsite for each control device. The Permittee shall record all
inspection; maintenance, and monitoring requirements listed above.
Reporting
Within 30 days after each calendar year,the Permittee shall submit emissions and/or operational data
listed below. The data shall include monthly and 12-month totals for the previous 12 month period.
The type and amount of fuel combusted in the boilers(ES-B-2 and ES-13-3).
The facility-wide sulfur dioxide, nitrogen oxides, carbon monoxide, VOC, highest individual
HAP, and total IJAP emissions.
Observed. The facility no longer combusts coal so there are no sulfur records for coal.
The permittee was not able to provide records of any inspections or maintenance done on the
bagfilters, cyclones, or multi-cyclone. However,Mr. Lewis stated the facility conducts maintenance
on the control devices more frequently than annually. During the inspection the control systems
appeared to be in good condition.
The annual report for calendar year 2021 was received by this office on February 17,2022 and
indicated compliance with the permit limits. Mr. Lewis was not able to provide records of monthly
emissions from January 2022 to date. However;the facility's emission history shows the emissions
are significantly below the permit limits. An NOD will be issued to the facility for failing to
maintain records.
n. Condition A.16. 15A NCAC 2D .0530 "Prevention of Significant Deterioration". In accordance with
15A NCAC 2Q .0317, to comply with this permit and avoid the applicability of 15A NCAC 2D ,0530
"Prevention of Significant:Deterioration," as requested by the Permittee, emissions shall be limited as
follows:
;Affected Source(s)=Pollutant*mission Limit(Tons Per Consecutive 12-month Period)
lFacility Wide S02 250
Observed. Historically, the facility's emissions are significantly below the permit limit. There are
no recordkeeping or reporting conditions with this stipulation. The facility is in compliance with the
emission limits identified in the Synthetic Minor condition(A.15). Therefore,the facility is in
compliance with this condition.

Bassett Upholstery Division
August 23, 2022
Page 12
p. Condition A.17. 15A NCAC 2Q .0711, "Emission Rates Requiring a Permit The facility must
comply with the following limits:
, �:_._ — -- --
Chronic Acute Acute
Pollutant Carcinogens Systemic
Toxicants Irritants
(lb/yr) (lb/day) Toxicants (lb/hr)
(lb/hr)
Ethyl acetate 147.41
�MEK(methyl ethyl ketone,2-butanone) 155.8 93.19
MIBK(methyl isobut 1 ketone 107.8 31.59��
Toluene 197.96 58.97
�Xylene(mixed isomers) 113.7 68.44
Observed. The facility is maintaining product usage records to ensure that the above limits are not
exceeded. Compliance is demonstrated.
8. NSPS/NES14AP Review
The facility no longer glues foam,and NESHAP Subpart 60 should be evaluated during the next permit
renewal.
This facility is not subject to the furniture MACT,NESHAP Subpart JJ, since the facility is not a major
source of HAPs.
The two existing boilers(ES-B-2 and ES-B-3)are subject to the Boiler NE'SI IAP Subpart 6J.
There are no generators at the facility and the fire-pump on site is electric,therefore the facility is not
subject to NESHAP Subpart 4Z.
The facility has a gasoline tank that has been disconnected,therefore is not subject to NESHAP Subpart
6C.
9. Summary of changes needed to the current permit:
ES-W-5 is not being used and may be removed the permit.
CD-F-1 is not being used and may be removed from the permit.
Add an enclosed trailer to the woodworking operations(ES-W-1).
Change description of control system for ES--W-1. Seethe detailed description for this source in Section
4 above.
These changes have been noted on the facility's yellowsheet.

i
Bassett Upholstery Division
August 23, 2022
Page 13
10. Compliance assistance offered during the inspection:
I discussed with Mr. Lewis the need for better recordkeeping.
11. Section 112(t)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 is not in compliance with the following:
- Condition A.14—NESI IAP 6J for failure to conduct a boiler tune-up within 25 months from the
previous tune-up.
- Condition A.15 -2Q .0315 —Synthetic Minor for failure to maintain records from January 2022
to the date of the inspection.
- Condition B.6—for failing to properly operate and maintain equipment at all times in a manner
that will effect an overall reduction in air pollution.
As a result, an NOV will be issued to Bassett Upholstery Division,Newton, Catawba County for violation of
Specific Condition and Limitation A.14. and General Condition and Limitation B.6.
An NOD will be issued to Bassett Upholstery Division,Newton, Catawba County for failing to maintain records
as required by Specific Condition and Limitation?A.15.
JEF:
cc: MRO File
https://neconnect.sharepoitit.com/sites/DAQ-MRO/Counties/CATAWBA/000I UINSPECT 20220823.doex