AQ_F_0200068_20211122_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Carpenter Company-Taylorsville Plant
NC Facility ID 0200068
Inspection Report County/FIPS:Alexander/003
Date: 11/18/2021
Facility Data Permit Data
Carpenter Company-Taylorsville Plant Permit 06822/R07
2581 Highway 90 East Issued 7/25/2014
Taylorsville,NC 28681 Expires 6/30/2022
Lat: 35d 54.9558m Long: 8ld 8.0022m Class/Status 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
Brooke Oldham Cliff Wilson Eric Houston MACT Part 63: Subpart 6J, Subpart 60
General Manager Division Manager Environmental Coordinator
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 11/18/2021
Inspector's Signature: zyum e Atiffi J99A Inspector's Name Ryan Mills
Operating Status Operating
Date of Signature:November 22, 2021 Compliance Status Compliance-inspection
Action Code FCE
Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2013 0.0200 0.3800 0.1100 11.13 0.0300 0.0200 68.00
2008 0.0200 0.3400 0.1000 12.38 0.0200 --- 58.90
*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

Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Tracking: Date submitted for initial review 11/22/2021 _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 11/01/2023
Directions:
From MRO,travel I-77 North,take I-40 West,take Hwy. 64 West,travel approximately 10 miles and turn
right onto Millersville Road,turn left onto Hwy. 90,travel approximately 1 mile and the facility is located
on the right at 2581 Highway 90 East.
Safety Equipment:
Safety glasses are required and safety shoes are recommended.
Safety Issues•
None noted.
Lat/Long Coordinates: A review of the "Facilities Regulated by Air Quality" on the DAQ web site indicates the
facility's location is accurate and matches the facility's latitude and longitude coordinates listed in IBEAM.No
changes to the latitude and longitude coordinates of this facility are needed in IBEAM. The latitude and longitude
coordinates of this facility are locked in IBEAM.
Email Contacts:
The email addresses were checked and appear to be accurate.No changes were needed.
COVID-19 Information:I contacted the facility to discuss their current policies concerning COVID.
The facility does not have any COVID restrictions at this time. I did a full inside inspection with my mask
on and observed social distancing guidelines.
1. The purpose of this site visit was to conduct a routine air quality inspection. This facility
manufactures, cuts and glues polyurethane foam to make foam products for use in the furniture
industry. The facility is currently operating 18 hours a day,Monday through Thursday. The
facility currently employs approximately 85 people.Mr. Jonathan Foster,Plant Manager,
accompanied me during this inspection.
2. Facility Contact Information:
During the inspection,I verified the facility contact information in IBEAM. No changes were
needed.
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 FEmission Source
Source ID Description
GB-1(NESHAP), GB-2 (NESHAP), GL-1 five (5)gluing stations using a total of 28 spray guns
(NESHAP), GL-2 (NESHAP),GL-3 installed on a polyurethane foam gluing process
(NESHAP)
Observed: Currently there are only three(3)gluing stations with a total of 15 spray guns. This is up
from 9 spray guns during the last inspection.Each line is connected to a separate fifty-five-gallon
drum of glue. All of the glue lines were in operation with no visible emissions. The facility uses glue
from Volunteer Adhesives(product ID VA-888). According to Mr. Foster,the plant currently sprays
approximately 150 gallons of glue per week. The facility keeps three barrels of adhesive on the floor
and three barrels in reserve at all times.
ES2 Solvent Cleaning
Observed: The plant uses Right Stuff(I. Schneider,Inc.—No. 4313)degreaser to clean glue gun
parts. The parts are soaked in a small(< 1 gallon)covered container. Mr. Foster indicated that the
facility uses less than 5 gallons of degreaser per year. The solvent cleaning operation is mobile and
moves around the plant.
5. Observations of insignificant air emission sources and control devices listed on the current permit:
Source I Exemption Regulation
IES I —No. 2 fuel oil-fired boiler(5.23 million Btu/hour maximum heat 2Q .0102(c)(2)(B)(i)(I)
input) subject to 40 CFR Part 63, Subpart JJJJJJ
Observed: The boiler(Cleaver Brooks—mfg date 8/17/1984)is used for comfort heat. The boiler
was operating during this inspection. The boiler is subject to the NESHAP 6J. Compliance with
the NESHAP is discussed in Item 7.g. of this compliance inspection report.
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 Emissions Inventory Requirement". At least 90
days prior to the expiration date of the permit,the Permittee shall submit a request for
permit renewal and an air pollution emission inventory report. The information shall be
submitted to the Regional Supervisor,DAQ. The report shall document air pollutants
emitted for the 2021 calendar year.
Observed: I reminded Mr.Foster that the emissions inventory would be due and that the
emissions from 2021 would be used in that inventory. Compliance with this condition is
indicated.
b. Condition A.3.— 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
condition is indicated.
C. Condition A.4.—"Notification Requirement". Notify DAQ of excess emission that last
more than four hours that result from a malfunction,a breakdown of process or control
equipment or any other abnormal conditions.
Observed: Mr. Foster stated that there had been no excess emissions to report.
Compliance with this condition is indicated.
d. Condition A.5.— 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission
Sources"requires the facility to develop and submit a fugitive dust control plan if the
facility cause or contribute to substantive dust complaints.
Observed: No complaints have been received regarding fugitive dust from this facility
during the last 5 years. No fugitive dust emissions were observed during the inspection.
Compliance with this condition is indicated.
e. Condition A.6.— 15A NCAC 2D .0958(c), "Work Practices for Sources of VOC's".
Observed: Alexander County is not one of the ozone non-attainment counties. This rule
should be taken out of the permit. The electronic yellowsheet has been updated in the
counties folder.
f. Condition A.7.—Generally Available Control Technology(GACT) -For the Flexible
polyurethane foam fabrication operations,Polyurethane Foam Gluing Process(ID Nos.
GB-1,GB-2, GL-1,GL-2 and GL-3),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." The Permittee is not allowed
to use any adhesive containing methylene chloride in the foam fabrication process. They
must maintain records to demonstrate compliance.
Observed: A review of the facility's records indicated that the adhesive does not contain
methylene chloride. The facility also has a letter(dated March 12,2021) on file stating
that no methylene chloride is used at the plant. Compliance with this condition is
indicated.
g. Condition A.8.—Federal and State Rules Applicable to Sources Exempted from Air
Permitting Requirements -the facility is subject to the following federal and state rules
which are applicable to some of the emission sources at the facility listed on the
"hisignificant/Exempt Activities" list attached to this permit.
40 CFR 63 -NESHAP/GACT--Subpart JJJJJJ--Industrial, Commercial and
Institutional Boilers at Area Sources

Observed: This rule applies to the No. 2 fuel oil-fired boiler(ID No. IES1- 5.23 million
Btu/hour maximum heat input). The facility submitted the required Initial Notification
on September 9,2011. The facility submitted the NOCS on July 11,2012. The boiler is
greater than 5 million Btu per hour and must conduct a biennial tune-up. Each biennial
tune-up must be conducted no more than 25 months after the previous tune-up. Facility
records indicate that the boiler was tuned-up on October 18, 2011, October 26,2012,
October 21, 2014, October 15, 2015, October 12,2016,December 15, 2017 and
November 11,2019,and November 10,2021. Mr. Foster indicated that they planned on
performing annual boiler tune-ups to avoid discrepancies or forgetting to complete this
requirement. Compliance with this permit condition is indicated.
8. NSPS/NESHAP Review:
The facility is subject to 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." This is discussed in Item 7.f. of this report.
The facility is subject to the NESHAP 6J. This is discussed in Item 7.g. of this report.
A fire pump is located in the front of the building; however,it runs on electricity. Also,no
gasoline storage tanks are located at this facility. (*Note that the facility does have a UST permit
posted near the entrance of the building,but the permit is for a fuel oil storage tank,not gasoline.
The permit was valid with an expiration date of 12/2001)
9. Summary of changes needed to the current permit:
Rule 15A NCAC 2D .0958(c), "Work Practices for Sources of VOC's" should be taken out of the
permit as Alexander county is not one of the ozone non-attainment counties
10. Compliance assistance offered duringtpection:
None needed or requested.
II. 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.
RCM:Ims
c: MRO File
https://neconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00068/INSPECT 20211118.doex