AQ_F_0200020_20220126_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Hancock&Moore,LLC dba Hancock&Moore
Plant 1
Inspection Report NC Facility ID 0200020
Date: 01/26/2022 County/FIPS: Alexander/003
Facility Data Permit Data
Hancock&Moore,LLC dba Hancock&Moore Plant 1 Permit 04852/R19
166 Hancock&Moore Lane Issued 8/24/2016
Hickory,NC 28603 Expires 7/31/2024
Lat: 35d 50.2998m Long: 81d 18.2700m 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
Kenneth Pennell Mark Cline Dennis Tart
Maintenance Supervisor Plant Manager Environmental Engineer
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 01/26/2022
7- Inspector's Name Karyn Kurek
Inspector's Signature: XafyrvK,IM ekl Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: 1/27/2022 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2015 0.3500 --- --- 23.98 --- --- 3474.59
2011 --- --- --- 24.68 --- --- 2032.24
*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

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dba Hancock&Moore Plant 1
January 26,2022
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Type X Full _Partial Compliance _Complaint Other:
Action: Compliance Evaluation/Reinspection Investigation
Evaluation
Data Date submitted for initial review 01/27/2022 IBEAM WARNING/OB,NOD,NOV,NRE
Tracking: 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
l/l/2024
Directions: From MRO,travel I-77 north to 1-40 west to Conover. Take Hwy. 16 exit and travel north
on Hwy. 16 toward Taylorsville. Travel approximately 9 miles and turn left onto Friendship Church
Road. Travel approximately 2 miles and turn left onto Church Road. Travel approximately 1 mile and
turn right onto Rink Dam Road. Travel approximately 4 miles and turn right onto Hwy 127. Travel
approximately 1 mile and turn right onto Teague Town Road,travel approximately'/4 mile and turn right
onto Hancock&Moore land. The facility is located on the right. (Important: The main office is in the
back of the facility, drive through the parking lot and around to the back of the building and find the door
that says, "Office")
Safety Equipment: Safety glasses and safety shoes are recommended.
Safety Issues:None noted.
Lat/Long Coordinates: A review of the facility's coordinates on DAQ's"Facilities Regulated by Air
Quality"website indicates the facility latitude and longitude coordinates are not listed,however the
location appears to be accurate.No changes to the latitude and longitude coordinates of this facility in
IBEAM are needed.
Email Contacts: IBEAM email contacts were reviewed and corrected in IBEAM.
Covid: Masks must be worn regardless of vaccination status.
1. The purpose of this site visit was to conduct a routine air quality inspection. This facility
manufactures upholstered furniture. The facility is currently operating forty hours per week, 50
weeks per year. I arrived at the facility on January 26,2022. Mr. Dennis Tart,Environmental
Engineer,accompanied me during this inspection. Mr. Tart confirmed that Hancock&Moore
employs approximately 210 people at Plant No. 1.
2. Facility Contact Information:
IBEAM email contacts were reviewed and corrected.
3. Compliance history file review:
On April 9,2018,the facility was issued a Notice of Deficiency for a late report. The Annual
report was due to MRO on March 1,2018.

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January 26,2022
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4. Observations of permitted air emission sources and control devices:
Emission FEmission Source Control Control System
Source ID Description System ID Description
S131, S1310, S132, ten(10)dry filter-type paint
SB3, SB4, SB5, spray booths
N/A N/A
SB6, SB7, SB8,
SB9
Observed.The facility currently has nine paint spray booths on site. Three(3) of the booths
were in operation with no visible emissions observed. All filters were in place and appeared to be
in good operating condition. Mr. Tart stated that the filters are replaced or cleaned weekly.
5. Observations of insignificant air emission sources and control devices listed on the current
>l ermit:
a. One(1)electric infrared drying oven which has been exempt from permitting per 2Q
.0102(g)(14)(B).
Observed.The electric infrared drying oven was observed operating at the time of
inspection with no issues noted.
6. Observations of air emission sources and control devices not listed on the current permit:
a. Hand-held sanding operations which vent to indoor filter systems.
Observed. The process was observed in operation with no problems noted.All filters
are changed out regularly. The sanding operation consists of approximately a dozen
individual stations with handheld sanders.
b. One(1)wash-off tank.
Observed. The unit was observed not in use.Acetone is used in the tank.Acetone is not
a regulated pollutant.
7. Compliance with specific permit conditions and limitations:
a. Condition A.2. - 15A NCAC 2Q .0304(d) and(f) "Permit Renewal and Emission
Inventory". The Permittee,at least 90 days prior to the expiration date of this permit,
shall request permit renewal by letter.
Observed.Permit 04852R19 was issued August 24,2016 and does not expire until July
31,2024.No action is required at this time. Compliance with this stipulation is indicated.
b. Condition A.3. - 15A NCAC 2D .0512 "Particulates From Wood Products Finishing
Plants". Provide adequate ductwork and properly designed collectors to control
woodworking particulates.

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dba Hancock&Moore Plant 1
January 26,2022
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Observed. The spray booths were properly maintained with no issues noted.Wood
particulate appeared to be properly controlled. No sawdust buildup was observed outside
the facility.No sources of dust exhaust to the outside atmosphere. Compliance with this
stipulation is indicated.
C. Condition AA. - 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 at the time of inspection.
Compliance with this stipulation is indicated.
d. 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. Tart,no excess
emissions have occurred at this facility. Compliance with this stipulation is indicated.
e. 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
boundary.
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.
f. Condition A.7. - 15A NCAC 2D .0958(c) "Work Practices for Sources of Volatile
Organic Compounds". Store all VOC-containing material in closed containers when not
in use, and clean spills and equipment properly.
Observed. The two mixing rooms where the paint is transferred from 50-gallon drums to
small containers for use within the plant were observed with no issues noted. All paint
containers were properly closed,wipe rags were stored in a closed container,both in the
mixing rooms and around the facility.No spills were observed. This rule no longer
applies because the facility is located in an area designated as attainment for ozone.
Compliance with this stipulation is indicated.
g. Condition A.8. - 15A NCAC 2Q .0711 "Emission rates requiring a permit. The facility
shall be operated and maintained in such a manner that emission of the TAPs listed in the
permit do not exceed the emission limits. The facility is required to maintain records to
demonstrate that TAPS emissions do not exceed the TEPRs listed in the permit.
Observed. Based on the 2015 emission inventory report received on August 17,2016,
all toxics were well below the required limits. In addition,the facility is tracking TAP
usage on a monthly basis to ensure `real-time' compliance. The most recent calculations

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dba Hancock&Moore Plant 1
January 26,2022
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are in the below table. A review of the monthly records indicated compliance.
Compliance with this stipulation is indicated.
Previous Inspection—for Nov 2019 Current Inspection—for Dec 2021
Pollutant lbs./day lbs./hr. lbs./day lbs./hr.
Ammonia 0 0 0.087 0.11
Ethyl acetate 2.313 0.289 3.44 0.43
Formaldehyde 0.005 0.001 0.007 0.001
MEK 5.842 0.730 6.532 0.816
MIBK 0.154 0.019 0.193 0.024
Manganese 0.191 0.024 0.008 0
Toluene 5.766 0.721 9.448 1.181
Xylene 1.371 0.171 2.377 0.297
h. Condition A.9. - 15A NCAC 2Q .0803 "Coating, Solvent Cleaning and Graphic Arts."
The facility is limited to potential emissions(defined as actual emissions)of less than 100
tons VOC, 10 tons of each individual HAP, and 25 tons of all HAPs combined. The
facility is required to submit an annual report by March 1 of each year summarizing the
VOC and HAP emissions for the previous calendar year.
Observed. The last required annual report was received on February 8,2021,reporting
VOC emissions of 36,837.99 lbs. (18.42 tons); combined HAPs emissions of 4,140.61
lbs. (2.07 tons);toluene emissions of 3,092.92 lbs. (1.55 tons); and xylene emissions of
573.82 lbs. (0.29 tons). Compliance with this condition is indicated.
8. NSPS/NESHAP Review
a. The facility does not conduct any foam production or fabrication and is not subject to
NESHAP Subpart 000000 Polyurethane Foam Production and Fabrication Area
Sources.
b. There are no emergency generators or fire pumps on site that could be subject to a
NSPS/NESHAP.
C. The facility does not have any gasoline storage tanks onsite; therefore,NESHAP 6C does
not apply.
9. Summary of changes needed to the current permit:
The 2D .0958 condition can be removed because it no longer applies to facilities located in areas
designated as attainment for ozone;this has been added to the yellowsheet.
10. Compliance assistance offered duringtpection:
No compliance assistance was offered during this inspection.

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January 26,2022
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H. Section 112(r)gpplicabilitX:
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.
KAK:Ims
cc:MRO File
https://neconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00020/INSPECT_20220126.doe