AQ_F_1800186_20211207_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Ramsey Finishing-Hickory
NC Facility ID 1800186
Inspection Report County/FIPS: Catawba/035
Date: 12/07/2021
Facility Data Permit Data
Ramsey Finishing-Hickory Permit 10616/R00
3060 Main Avenue SE Issued 6/7/2019
Hickory,NC 28602 Expires 5/31/2027
Lat: 35d43.5191m Long: 8ld 16.2108m Class/Status Small
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
Kipp Hubbard Chris Ramsey Shane Houston
Customer Management Owner Operations Manager
Executive [phone] [phone]
[phone]
Compliance Data
Comments:
Inspection Date 12/07/2021
Inspector's Signature: zyum e Atiffi 1�9:( Inspector's Name Ryan Mills
Operating Status Operating
Date of Signature:December 11, 2021 Compliance Status Compliance-inspection
Action Code FCE
Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2011 --- --- --- --- --- --- 1567.84
2006 --- --- --- --- --- --- 2138.15
*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

Ramsey Finishing
December 7,2021
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Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Tracking: Date submitted for initial review 1/8/2020 _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 12/1/2023
Directions:
From MRO,travel I-77 north to I-40 West to exit 130 (Old Hwy 70). Turn right onto West lst Street then
continue onto Tate Blvd. Turn right onto 3 Pt St. Place SE and then turn left onto Main Ave. SE. The
facility will be on the left.
Safety Equipment:
No safety equipment is required by the facility. However, safety glasses, safety shoes and ear protection
are recommended.
Safety Issues•
None noted.
Facility LAT/Long:
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 facility email contacts were checked and the Facility contact has changed and as such the email was
updated in IBEAM.
COVID-19 Information: I contacted the facility to discuss their current policies concerning COVID. The
facility has no policies in place currently. 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 coats
furniture frames with different lacquers and stains. The facility is currently operating 46 hours per
week. The normal operating schedule is 6-4:30 Monday through Thursday and 6-Noon on Friday.
The facility currently employs approximately 25 employees. Mr. Kipp Hubbard,Customer
Management Executive, accompanied me during this inspection.
2. Facility Contact Information:
During the inspection,I verified the facility contact information in IBEAM. The facility contact
was changed to Mr.Kipp Hubbard, Customer Management Executive.

Ramsey Finishing
December 7,2021
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3. Compliance history file review.
This is a new permit which was issued on June 7,2019. The current compliance status is
discussed in the following sections.
4. Observations of permitted air emission sources and control devices:
Emission Emission Source Control Control System
Source ID Description System ID Description
ES-1 wood dust collection CD-I,CD-2 cyclone(126 inches in diameter)
system installed in series with fabric filter
(7,163 square feet of filter area)
Observed.The facility does not have any plans to operate any of the equipment associated with the
wood dust collection system including the cyclone and bagfilter controls. These two emission sources
were on the property when they bought it. During this inspection the control devices CD-1 and CD-2
were not in operation.Also, emission source ES-1 was not in operation.
SB-I, SB-2, SB-3, SB-4, seven(7)dry filter type
SB-5, SB-6, SB-7 spray booths installed on N/A N/A
a wood furniture
finishing operation
Observed.The facility is permitted for seven(7)dry filter type spray booths. All seven(7) spray booths
were in operation during this inspection. All filters were in place and appeared to be in good operational
condition. The facility brought me to the chemical storage room to show me the coatings used on the
furniture. The coating used the most is lacquer made by Carolina Solvents with Lot No. 2101789 as of
8/16/2021.
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?
I-B 1 -natural gas-fired boiler(1.75 million Btu per 2Q .0102 Yes Yes
hour maximum heat input rating) �(h)(I)(B)
I-B2 -natural gas-fired boiler(0.675 million Btu 2Q .0102 Yes Yes
per hour maximum heat input rating) �(h)(I)(B)
Observed.The boilers were in operation with no issues and are both used for comfort heat.
6. Observations of air emission sources and control devices not listed on the current permit:
None observed.
7. Compliance with specific permit conditions and limitations:
a. Condition A.3. 15A NCAC 2D .0512 "Particulates from Wood Products Finishing
Plants". The permittee shall not discharge particulate matter caused by the working,
sanding or finishing of wood without providing, as a minimum for its collection,

Ramsey Finishing
December 7,2021
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adequate duct working and properly designed collectors, or other such devices as
approved by the Commission.
Observed. The permit states that the inspection,maintenance and record keeping
requirements shall become effective immediately if the facility begins operating the
wood dust collection system(ID No. ES-1) for production purposes. The facility is not
currently operating(ID No. ES-1) and as such compliance will be evaluated when and if
the facility begins using these control devices. The facility is,however,using the spray
booths. All dry filters were in place and appeared to be maintained properly.No
overspray was observed and no visible emissions were coming out of the stacks.
Compliance with this permit condition is indicated.
b. Condition A.4. 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.5. 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 conversation with Mr. Hubbard,no excess
emissions have occurred at the facility since the facility started up in June of 2019.
Compliance with this condition indicated.
d. Condition A.6. 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission
Sources." The Permittee shall not cause or allow fugitive dust emissions to cause or
contribute to substantive complaints or excess visible emissions beyond the property
boundaries.
Observed. The MRO has not received any complaints regarding the facility and no
fugitive dust emissions were observed at the time of this inspection. Compliance with
this condition is indicated.
e. Condition A.7. &A.8. Cyclone and Fabric Filter Requirements. Conduct an annual
internal inspection of the bagfilter systems and an annual inspection of the cyclone
system. Conduct periodic inspections and maintenance as recommended by the
equipment manufacturer and list corrections made and dates of actions in a log book.
Observed. The permit states that the inspection,maintenance and record keeping
requirements shall become effective immediately if the facility begins operating the
wood dust collection system(ID No. ES-1)for production purposes. The facility is not
currently operating this system and as such compliance with this permit condition will be
evaluated when and if the facility begins using these control devices. Compliance with
this condition is indicated.

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December 7,2021
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f Condition A.9. 15A NCAC 21) .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.No odors were detected outside the facility. As I toured the coating operation,
minimal odors were detected inside the facility and appeared to be well controlled by
housekeeping practices.
g. Condition A.10.—Pursuant to 15A NCAC 2Q .0711 "Emission Rates Requiring a
Permit," for each of the below listed toxic air pollutants(TAPs),the Permittee has made a
demonstration that facility-wide actual emissions,where one or more emission release
points are obstructed or non-vertically oriented, do not exceed the Toxic Permit Emission
Rates(TPERs)listed in 15A NCAC 2Q .0711(a). The facility shall be operated and
maintained in such a manner that emissions of any listed TAPS from the facility,
including fugitive emissions,will not exceed TPERs listed in 15A NCAC 2Q .0711(a).
a. A permit to emit any of the below listed TAPS shall be required for this facility if actual
emissions from all sources will become greater than the corresponding TPERs.
b. PRIOR to exceeding any of these listed TPERs,the Permittee shall be responsible for
obtaining a permit to emit TAPs and for demonstrating compliance with the requirements
of 15A NCAC 2D .1100 "Control of Toxic Air Pollutants".
c. In accordance with the approved application,the Permittee shall maintain records of
operational information demonstrating that the TAP emissions do not exceed the TPERs
as listed below:
Chronic Acute Acute
Pollutant Toxicants Systemic Irritants
(lb/day) Toxicants (lb/hr)
(lb/hr)
Ethyl acetate(141-78-6) 36
Formaldehyde(50-00-0) 1 0.04
MEK(methyl ethyl ketone,2-butanone)(78-93-3) 78 1 22.4
MIBK(methyl isobutyl ketone)(108-10-1) 52 7.6
Toluene (108-88-3) 98 14.4
Xylene(mixed isomers)(1330-20-7) 57 16.4
Observed: The facility is keeping invoices for the paints and coatings being used at the
facility. I reviewed the invoices going back to June of 2019 from Carolina Solvents. The
permit review conducted on June 7,2019 indicates the actual toxic emissions are
substantially below the TPER limit. As a result, it does not appear the facility has
exceeded the TPER limits. Compliance with this condition is indicated.

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h. Condition A.11. 15A NCAC 2Q. 0803 `Exclusionary Rule Requirements",potential
emissions shall be determined using actual emissions without accounting for any air
pollution control devices. As required by 15A NCAC 2Q .0803,the facility potential
emissions(defined as actual emissions) shall be less than the following:
i. 100 tons per year of volatile organic compounds(VOC);
ii. 10 tons per year of each hazardous air pollutant(HAP); and
iii. 25 tons per year of all HAPs combined.
Observed.During 2020,the facility used 43,995.1 pounds or 21.99 tons of VOC's. The
greatest quantity of an individual HAP was 4,826 pounds or 2.4 tons of toluene. The total
pounds of all HAP's combined was 11,220.8 pounds or 5.6 tons. Compliance with this
condition is indicated.
As required by 15A NCAC 2Q .0803,the Permittee shall comply with the following
requirements:
iv. Annual Report Requirement-By March 1 of each year,regardless of the actual
emissions,the Permittee shall submit to the Regional Supervisor,DAQ, a report
summarizing emissions of VOC and HAPs containing the following:
A. the pounds of VOC used during the previous calendar year;
B. the greatest quantity in pounds of an individual HAP used during the
previous calendar year; and
C. the total pounds of all HAPs used during the previous calendar year.
Observed.We have received reports from the facility on February 10,2020 and February
8,2021. Compliance with this condition is indicated.
V. Records Maintenance Requirement-The Permittee shall maintain purchase
orders and invoices of materials containing VOC. These purchase orders and
invoices shall be maintained for a period of at least three years and be made
available to DAQ personnel upon request.
vi. Notification Requirement-The Permittee shall report to the Regional Supervisor,
DAQ, any exceedance of a requirement of rule 15A NCAC 2Q .0803 within one
week of occurrence; and
vii. Certification Requirement-The Permittee shall certify all submittals as to the
truth, completeness,and accuracy of all information recorded and reported over
the signature of the appropriate official as identified in rule 15A NCAC 2Q
.0303(4).
Observed.The facility had the invoices and a summary sheet of"product VOC
information" from Carolina Solvents,Inc. for 2019,2020 and 2021. Compliance with this
condition is indicated.

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December 7,2021
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8. NSPS/NESHAP Review
The natural gas-fired boilers are not subject to NSPS Subpart Dc since they are both rated at
below the 10 million Btu per hour applicability threshold.
The facility is not subject to the wood furniture NESHAP Subpart JJ, since the facility is
not a major source of HAPs. The natural gas-fired boilers are not subject to the area source boiler
NESHAP Subpart JJJJJJ,since they only combust natural gas. The facility is not subject to Subpart
000000 since the facility will not apply glue to foam.
There are no emergency generators, fire pumps or gasoline storage tanks at this facility.
9. Summary of changes needed to the current permit:
None at this time.
10. Compliance assistance offered duringthe hpection:
None offered or requested.
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.
RCM:lms
cc:MRO File
https://neconnect.sharepoint.com/sites/DAQ-MRO/Counties/CATAWBA/00186/INSPECT 20211207.doex