AQ_F_1400008_20220512_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Bernhardt Furniture Company-Plants 2&5
NC Facility ID 1400008
Inspection Report County/FIPS: Caldwell/027
Date: 05/10/2022
Facility Data Permit Data
Bernhardt Furniture Company-Plants 2& 5 Permit 01755/R22
1828 Morganton Boulevard Issued 1/21/2015
Lenoir,NC 28645 Expires 12/31/2022
Lat: 35d 53.9275m Long: 81d 33.3791m Class/Status Synthetic Minor
SIC: 2511 /Wood Household Furniture Permit Status Active
NAICS: 337122/Nonupholstered Wood Household Furniture Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Eddie Pitts Peter(Pete)Craymer Eddie Pitts MACT Part 63: Subpart 6J, Subpart JJ
Corporate Environmental Chief Financial Officer Corporate Environmental
Manager and Senior VP Manager
[phone] [phone] [phone]
;. Compliance Data
Comments:
Inspection Date 05/12/2022
Inspector's Name Patrick Ballard
Inspector's Signature: Operating Status Operating
Compliance Status Compliance- inspection
Action Code FCE
Date of Signature: Cl� Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2013 3.16 0.1100 2.10 25.30 2.57 2.91 2579.78
2008 3.75 0.6000 4.23 15.21 5.06 2.82 1705.48
X Highest HAP Emitted(in pounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE: None
Date Test Results Test Method(s) Source(s)Tested
L--
Directions: Facility is located on HWY 18 north of Lenoir(but south of the 321 By-pass). The order of plants on the street is
Bernhardt Plants 5, 6, 2; Virginia Street; Minton ventures (formerly Bernhardt Plant I) and Bernhardt Plants 3 and 7.
Safety Equipment: Shoes, glasses and hearing protection.

1. On May 10,2022 I met with Eddie Pitts to conduct a routine air quality inspection of the Bernhardt Furniture
Plants 2 and 5 facility in Lenoir,Caldwell County,North Carolina. This facility manufactures wood furniture.
This facility is divided into two plants,Nos.2 and 5. Plant 5 manufactures chair legs and upholstery frames.
Plant 6(not permitted),which is adjacent to Plant 5, is an upholstery plant where the frames made at Plant 5 are
upholstered. Plant 2 has shut down production operations and is primarily a warehouse. With the shutdown of
Plant 2,the facility was reclassified from Title V to Synthetic Minor with the issuance of Permit 01755R20 on
February 29,2008. However,the facility remains subject to MACT, Subpart JJ for the finishing operations.
2. The followinjz permitted air emission sources were observed as follows:
a. PLANT 2:
Production at Plant 2 ended the first week of June 2005. Plant 2 is being used as a warehouse and
distribution center for imported furniture. The facility continues to be permitted to operate the following
equipment:
i. Three spraybooths ID Nos.226,240 and 241)and Wash off Tanks(ID Nos.271 and 272)
Spraybooth 226 has been removed from the facility. Spraybooths 240 and 241 are used for touch-
up of imported furniture but were not in operation during the inspection. The spraybooths have
baffles or metal filters and one stack each. MACT, Subpart JJ requires monthly inspections of the
spraybooths,including leak inspections. All records of inspections were adequate and up to date.
Because Spraybooth 226 has been removed,records on this booth are currently not being kept. If
this booth goes back into operation,then maintenance records will have to be resumed. There is
no wash-off conducted at Plant 2,except with acetone(which is exempt). Two wash-off tanks
remain at the plant but were not in use. They continue to be listed on the permit. Spraybooths 240
and 241 were subject to a 40 ton per year VOC PSD avoidance limit. However,because of the
greatly reduced usage,the facility submitted a permit modification request in 2006 to have this
requirement removed. The current permit retains the 40 ton per year limit,but the reporting
requirement has been removed.
ii. Bagfilter 219 and Cyclone 203
Bagfilter 219 continues to operate for some woodworking equipment in a mockup lab. The
bagfilter was in operation during the inspection with no visible emissions from the main exhaust.
Collected wood dust from this bagfilter drops into a truck bed. The truck loading operation is
enclosed with a new feed system(installed in about 2016). An annual internal inspection of the
bagfilter was conducted on June 5,2021. The cyclone is no longer used.
iii. The boilers and lumber kilns have been removed from the permit and are no longer in operation.
iv. Located at Plant 2 are two R&D spraybooths exempt from permitting per 2Q .0 1 02(g)(3)(B).
Also,40 CFR 63.800(c)exempts research and laboratory spraybooths from MACT Subpart JJ.
b. PLANT 5:
i. Boiler and Woodworking
Observations of the boiler and woodworking operations during the inspection are summarized in
the following table:

E ui ment Comment
Boiler ES-515 Woodwaste/Coal boiler 25 mmBtu/hr. Not operating during the inspection. The
boiler is typically used during the colder months for building heat. Boiler
manufacture date- 1968. Firetube boiler. The facility has not received any coal in
several years. The current permit has a 0.88%sulfur synthetic minor limit. The
last annual internal inspection of the multicyclone(CD-515)was conducted on
April 8,2022. See additional comment on the boiler below.
Bagfilter CD-501 Operating with no visible emissions. Located on the ground.
Cyclone CD-503 This cyclone is no longer used. Located on the ground.
Cyclone CD-506 Operating, venting to Bagfilter CD-507. Located on the roof.
Bagfilter CD-507 Operating with no visible emissions. Located on the ground.
Unlisted Cyclones At the facility are one unused cyclone CD-505 and one closed loop cyclone CD-
504. These cyclones are not listed on the permit. Both are located on the roof.
No leaks were observed in the woodworking or boiler ductwork or control equipment. The last
annual inspection of the bagfilters and cyclones was on April 7,2022. Bagfilters require an
internal inspection,cyclones are not typically designed for internal inspections. The facility
continues to conduct monthly external visual inspections of the bagfilters and cyclones(this is a
carryover from when the facility was Title V.
Boiler GACT
The facility is subject to the requirements of GACT 6J for the Boiler ES-515. The initial
compliance notification was received on November 1,2011 (see file). An initial boiler tune-up
was due by March 21,2012 and then every 25 months thereafter. Boiler tune-ups have been
conducted as follows:
January 5,2012
February 21,2014
November 14,2016(delayed because boiler was shut down)
November 27,2018
September 9,2020.
A one-time energy assessment was due by March 21,2014 and was conducted on January 19,
2012.
Boiler Coal Usage
The current permit includes the combustion of coal in the boiler,with combustion limited to 626
tons per year at a maximum 0.88%sulfur. The facility has not received any coal in several years.
Boiler Stack Test
The 2D .0504 particulate limit for Boiler ES-515 while combusting wood is 0.57 lb/mmBtu. On
March 11,2014,this boiler stack tested at 0.57 lb/mmBtu(see file). Because the boiler stack
tested at the limit,Permit 01755R22 requires an additional stack test,with a due date of December
31,2016. This stack test was conducted on November 16,2016 and the boiler tested at 0.388
lb/mmBtu(see file).
ii. Finishing
The finishing operation consists of eight (8) baffle-type spray booths (ES-520 to ES-527), one
automated chair leg finishing system consisting of two dry filter-type spray booths (ES-528 and
ES-529), one drying oven(ES-530)and one washoff tank(ES-531). Observations of the finishing
operations during the inspection are summarized in the following table. Except for the automated
chair leg system,the conveying system is all push carts. There is no pump room for this plant,just
a storage room.

ID No, Coating type Gun type No.of Operators Product Lb�VH 'flb
Number solids
520 Lacquer AAA Kathy Browning T75FH71 0.19
521 Repair Booth Not
Operating
522 Repair Booth Not
Operating
523 Dusty Wax cup gun 912-2230 0
524 Stain HVLP Gilberto Cespedes 434-2557 0.02
(8 psi)
525 Sealer AAA Robert Earp T65FH14 0.40
526 Glaze HVLP Susan Perkins 560-7040A 0
(5 1/2 psi)
527 Lacquer AAA T75FH71 0.19
528 Automated chair leg HVLP Cindy Townsend 450-6883 0.37
(Base Coat) (4 psi)
529 Automated chair leg AAA T75FH71 0.19
(Lacquer)
Drying steam heat
Oven 530 (not used)
Boothcoat M55C0009 0.01 lb VOC/lb
solids
Washoff Not used(a small
Tank amount of washoff is
conducted using
acetone(HAPs free)
Thinner 480-1847 <1%VHAP
Gluing PVA(conducted
throughout the facility)
iii. MACT Check List Results:
A. Finish/solvent/adhesive records [63.806(b)].
Certified product data sheets(CPDS)for each finishing material,thinner,and strippable spray
booth coating subject to the limits were available. A random check of finishes reviewed
indicated compliance with the 1 lb VHAP/lb solid limit(see table above). The Strippable
Booth Coat contains 0.01 lb VOC/lb solid. No contact adhesives are used at this plant.
Formaldehyde is limited to 1.0%by weight or 400 pounds per year. Formaldehyde emissions
of 42.35 pounds are reported in the 2020 annual synthetic minor report(received 01/21/2022,
see facility file(note,this also includes combustion emissions)).
B. Work practice implementation plan[63.803(a)].
1. The facility provided a list of employees with training records [63.803(b)]. The last
annual training was October 27,2021.
2. Inspection and maintenance plan[63.803(c)].
MACT, Subpart JJ,requires monthly inspections of the spraybooths, including leak
inspections. Inspection reports were reviewed and appeared to be adequate. No
problems have been noted.
3. Cleaning and washoff solvent accounting system [63.803(d)].
The facility uses acetone(non-HAP/VOC)solvent for washoff.
4. Formulation Assessment Plan for finishing operations [63.803(1)].
Reviewed and appeared adequate(see facility file, last received 07/26/2021).
C. Spray booth cleaning[63.803(f)].
This facility does not use anything but the strippable booth coat.
D. Storage requirements(solvent containers without lids are NOT allowed) [63.803(g)].

All containers observed were closed. All containers at the spray booths were observed closed.
E.Application equipment requirements [63.803(h)]. The use of"conventional"air spray guns are
not allowed unless emissions are vented to a control device. There are no VOC emission
control devices at this facility. The facility is using all HVLP, air assisted airless or airless
guns. The air pressure limit for HVLP spray guns is 10 psi. A random check of HVLP spray
guns indicated air pressures less than 10 psi(see table above).
3. The followiniz nonpermitted air emission sources were observed as follows:
Listed on permit as an insignificant activity—one natural gas-fired boiler(8.375 mmBtu/hr)—not in operation and not
even hooked up. Boiler plate date: 9/25/69.
4. Recordkeeping and Reporting Requirements:
a. Synthetic Minor Limits: This facility was reclassified from Title V to Synthetic Minor with the issuance of Permit
01755R20 on February 29,2008. Woodwaste combustion is limited to 10,159 tons per year. Coal combustion is
limited to 626 tons per year at a maximum 0.88%sulfur. VOC emissions are limited to less than 100 tons per year.
HAP emissions are limited to 10 tons per year for any single HAP and 25 tons per year for total HAPs. The synthetic
minor annual report for 2021 (due by January 30,2022 and received on 01/21/2022)indicated 599 tons of wood
combusted and no coal combusted. VOC emissions from 2021 were 11.11 tons while the largest HAP(toluene)
emissions were 0.21 tons. Total HAP emissions were 0.91 tons per year. The bagfilters,cyclones and multicyclones
are subject to inspection and maintenance(I&M)requirements. Compliance with the I&M requirements was
indicated during the inspection(see above).
b. PSD Avoidance Limits: The facility retains subject to a 40 tpy VOC limit for spraybooths ES-240 and ES-241.
However,because of the greatly reduced usage,the reporting requirement for this condition has been removed. The
recordkeeping requirement remains in the permit.
c. NESHAP Semi-Annual Compliance Certification: The facility remains subject to MACT, Subpart JJ for the
finishing operations,which requires Semi-Annual Compliance Certification. This report is due January 30 and July 30
of each year. This report was last received on 01/21/2022. No deviations were noted.
5. Compliance History
There have been no documented air quality compliance issues at this facility in the past five years. A summary of
compliance problems which resulted in NOVs during the past several years is tabulated below:
Inspection/Test Notice of Violation Description of violation(s)
01/28/2009 02/05/2009 NOV issued for violation of the 0.88% coal sulfur synthetic
minor limit.
03/22/2006 04/10/2006 NOV for failure to conduct weekly inspections of spraybooths.
NA 11/30/2004 NOV(issued by RCO)for late submittal of annual report to EPA.
NA 11/16/04 NOV/NRE for failure to timely submit a quarterly report. The
company was assessed$1000 for this violation.
8/24/04 9/13/04 NOV/NRE for permit recordkeeping on Boiler ID No. 515. The
company was assessed$5000 for this violation.
MACT Subpart JJ Requirements (tip pressure). The company
was assessed$4000 for this violation.
NA 6/16/04 NOV for failure to timely submit a quarterly report
9/15/03 10/16/03 NOV/NRE for Permit Recordkeeping and MACT Subpart JJ
Requirements (tip pressure). The company was assessed $5400
for this violation.
NA 4/4/03 Failure to include NOV in compliance certification
7/31/02 8/9/02 NRE for MACT Recordkeeping
7/24/2001 11/06/2001 Emissions from Boiler ID No. 221 in excess of 2D .0504 limit

Inspection/Test Notice of Violation Description of violation(s)
during 7/24/2001 Method 5 stack test.
4/10&11/2001 07/02/2001 Emissions from Boiler ID Nos. 221 and 515 in excess of 2D
.0503 limits during 4/10 and 4/11 Method 5 stack tests.
01/31/2001 02/13/2001 Visible emissions violation documented on Boiler ID No. 515.
09/29/1999 10/14/1999 Visible emissions violation documented on Boiler ID No. 515.
04/01/1999 04/20/1999 Visible emissions violation documented on Boiler ID No. 515.
01/07/1999 01/08/1999 Visible emissions violation documented on Boiler ID No. 515.
12/18/1997 01/30/1998 Violation of 2D .0512 citing several sources of excessive fugitive
wood dust coming from the facility
04/16/1997 04/28/1997 Visible emissions violation documented on Boiler ID No.220.
6. This facility does not appear to be subject to the requirements of 112(r).
Based on my observations during the inspection,Bernhardt Furniture Plants 2 and 5 appeared to be in compliance
with the applicable air quality regulations and Air Permit No. 01755R22 during this inspection. No permit
modifications were determined to be necessary at the time of the inspection.