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Home My WebLink AboutAQ_F_0200089_20210721_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office AIR QUALITY Royale Comfort Seating,Inc. -Plant No. 1 NC Facility ID 0200089 Inspection Report County/FIPS:Alexander/003 Date: 07/7/2021 Facility Data Permit Data Royale Comfort Seating,Inc. -Plant No. 1 Permit 08939/T04 141 Alspaugh Dam Road Issued 7/10/2018 Taylorsville,NC 28681 Expires 6/30/2023 Lat: 35d 52.2612m Long: 81d 11.5368m Class/Status Title V SIC: 3086/Plastics Foam Products Permit Status Active NAILS: 32614/Polystyrene Foam Product Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP/Title V Lee Isenhour Clyde Goble Lee Isenhour HR and Safety President HR and Safety (828)632-2865 (828)632-2865 (828)632-2865 Compliance Data Comments: Inspection Date 07/07/2021 Inspector's Name Emily Supple Inspector's Signature: &n4 I Suppee V/M Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: 7/21/2021 Inspection Result Violation Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2019 --- --- --- 9.52 --- --- 17743.00 2018 --- --- --- 26.20 --- --- 48360.00 2017 --- --- --- 15.20 --- --- 28005.00 *Highest HAP Emitted inpounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 09/24/2020 NOV/NRE Permit Late Report(excluding ACC) 10/05/2020 03/12/2019 NOV Permit Late Title V ACC 03/18/2019 03/06/2017 NOV 2Q .0803 Coating, Solvent Cleaning,Graphic Arts 03/28/2017 Operations Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested Royale Comfort Seating,Inc. -Plant No. 1 July 7, 2021 Page 2 Type X Full Compliance _Partial Compliance _Complaint Other: Action: Evaluation Evaluation/Reinspection Investigation Data Date submitted for initial review 07/16/2021 X IBEAM WARNING/OB,NOD,NOV,or NOV/NRE Tracking: 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 07/01/2022 Directions: From MRO,travel I-77 north to I-40 west. Take Hwy. 16 exit and travel north for approximately 12 miles. Turn left onto Alspaugh Dam Road. The facility is located on the right at 141 Alspaugh Dam Road. Safety Equipment: Safety glasses are recommended. Safety Issues: None noted. Lat/Long Coordinates: A review of the facility's coordinates on "Maps of DAQ Regulated Facilities" indicates the facility's latitude and longitude coordinates are accurate. Email contacts: No changes were needed at this time. 1. General Information: The purpose of this site visit was to conduct a routine air quality inspection. I arrived at the facility around 10:00 am on July 7, 2021. This facility cuts and glues foam for chair cushions. The facility is currently operating forty hours per week. Mr. Bradley Looper, Plant Manager,accompanied me during this inspection. 2. File Review. A. Contacts. During the inspection, I verified that the facility contact information in IBEAM was correct. B. Files. The following files were reviewed prior to the inspection: current permit, previous inspection reports, quarterly, semiannual, and annual reports, and annual emissions inventories. C. Compliance history: The facility was issued a Notice of Violation with Recommendation for Enforcement (NOV/NRE) on November 21,2014 for operations exceeding the HAP 10 tons per 12-month period Title V threshold level with trichloroethylene. The facility was issued a Notice of Deficiency(NOD)on March 17, 2016 for a late annual report of VOCs and HAPs. The report was received March 28, 2016. The facility was issued a Notice of Violation(NOV)on March 6,2017 for late submission of the VOC and HAP emissions report. Royale Comfort Seating,Inc. -Plant No. 1 July 7, 2021 Page 3 The facility was issued an NOV on March 12, 2019 for late submission of their annual compliance certification(ACC). The facility was issued an NOV/NRE on September 24, 2020 for late submission of the semiannual VOC and visible emission reports. D. NSPS/NESHAP Review There are no emergency generators or fire pumps on site; therefore the facility is not subject to NESHAP 4Z. There are no boilers onsite; therefore the facility is not subject to NESHAP 6J. The facility does not have any gasoline storage tanks onsite; therefore they are not subject to NESHAP 6C. 3. Part I-AIR QUALITY TITLE V OPERATION PERMIT. The following permitted emission sources and/or control devices listed in Section 2 Paragraph 2.1-Emission Source(s) and Control Devices(s) Specific Limitations and Conditions were observed during this inspection: Emission Control Source Device ID No. Emission Source Description ID No. Control Device Description ES-2 Foam Fabrication Process N/A N/A consisting of Glue Spraying Operation Observed. The facility operates glue stations with sixteen HVLP glue guns. Two stations were observed in operation with no visible emissions or odors noted. 1. 15A NCAC 2D .0515: Particulates from Miscellaneous Industrial Processes Emissions of particulate matter from this source (ID No. ES-2) shall not exceed an allowable emission rate. a. The Permittee shall maintain production records such that the process rates "P" in tons per hour, as specified by the formulas contained above can be derived and shall make these records available to a DAQ authorized representative upon request. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if the production records are not maintained or the types of materials and finishes are not monitored. b. No reporting is required for particulate emissions from this source(ID No.ES-2). Observed. The facility keeps records of the amount of adhesive used in gallons. An SDS is kept on site for the glue such that tons per hour can be calculated. They used around 4,525 gallons of material in 2020, and 1,740 gallons through May 2021. As per the permit review for R03 on April 20, 2017, it is indicated that there is a small amount of solids (less than 0.1 lb/gal) contained in the adhesive for a total of 452.5 pounds of solids in the year 2020 (about 0.23 lb/hour based on 2,000 hours of operation per year) and 174 pounds of solids in the year 2021 (about 0.22 lb/hour based on 40 hours of operation per week for about 20 weeks). The facility is well under the allowable emission rate. Compliance is indicated. Royale Comfort Seating,Inc. -Plant No. 1 July 7, 2021 Page 4 2. 15A NCAC 2D .0521: Control of Visible Emissions Visible emissions from this source (ID No. ES-2) shall not be more than 20 percent opacity when averaged over a six-minute period. a. To ensure compliance, once a month the Permittee shall observe the emission points of this source (ID No.ES-2) for any visible emissions above normal. The monthly observation must be made for each month of the calendar year period to ensure compliance with this requirement. The results of the monitoring shall be maintained in a logbook (written or electronic format)on-site and made available to an authorized representative upon request. b. The Permittee shall submit a summary report of the monitoring and recordkeeping activities given in the permit, postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. Observed. The facility was observed operating without any visible emissions occurring. The facility keeps a logbook with visible emission observations. I reviewed visible emissions observations from January 2019 through April 2021. The most recent observation was conducted in April of 2021. No observations had been recorded for the months of May or June. Summary reports were received on January 30, 2021 and October 5, 2020 (late report) but did not contain the summary information for visible emissions. I explained to Mr. Looper that the reports need to contain this information, and I sent an email on July 12, 2021 explaining this to the facility. The facility is in violation of this condition for failure to record monthly visible emission observations. 3. 15A NCAC 02D .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.I did not experience any odors off property and this office has not received any odor complaints since the last inspection. Compliance was indicated. 4. 15A NCAC 02Q .0317 PSD Avoidance for 15A NCAC 02D .0530: Prevention of Significant Deterioration To avoid applicability of 15A NCAC 02D .0530: Prevention of Significant Deterioration, the volatile organic compound (VOC) emissions from this source (ID No. ES-1) shall be less than 250 tons per consecutive 12-month period. a. Calculations of VOC emissions per month shall be made at the end of each month. VOC emissions shall be determined by multiplying the total amount of each type of VOC- containing material consumed during the month by the VOC content of the material. b. Calculations and the total amount of VOC emissions shall be recorded monthly in a logbook (written or electronic format). Royale Comfort Seating,Inc. -Plant No. 1 July 7, 2021 Page 5 c. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of monitoring and recordkeeping activities given in the permit, postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December, and July 30 of each calendar year for the preceding six-month period between January and June. The report shall contain the monthly VOC emissions for the previous 17 months. The emissions must be calculated for each of the 12-month periods over the previous 17 months. Observed. Records of VOC emissions calculations are being kept. I observed the monthly VOC calculations based on material used through May 2021. The most recent report was received on January 30, 2021. It was discovered that the facility is calculating the VOC emissions incorrectly. The SDS indicates that the glue is 50-75% VOC. The facility was using an assumption of 59% VOC to calculate emissions. However, the facility needs to use the worst-case assumption of 75% VOC in their emissions calculations. This was explained to Mr. Looper while on site, and I sent an email on July 12, 2021 explaining the correct calculations to the facility. Compliance with this condition is indicated. 4. Part II-AIR QUALITY TITLE V OPERATION PERMIT. Section 3 -GENERAL CONDITIONS A. Permit. Maintain a copy of the permit and application at the facility. Observed. The permit and application are kept at the facility. B. Submissions. Except as otherwise specified, two copies of all documents, reports, test data, monitoring data are required to be submitted to MRO. Observed. The company has been complying with this requirement. C. Circumvention. Operate and maintain the facility at all times in a manner that will affect an overall reduction in air pollution. Observed. The facility appears to comply with this requirement. D. Excess Emissions. Report excess emissions and permit deviations as required. Observed. No excess emissions have occurred. Compliance is indicated. E. Retention of Records. The Permittee shall retain records of all required monitoring data and supporting information for a period of at least five years from the date of the monitoring sample, measurement,report, or application. Observed. Records are being maintained. F. Compliance Certification. By March 1 submit a compliance certification (for the preceding calendar year). Observed. The facility indicated that they sent the ACC on February 22, 2021, but MRO did not receive it. The facility re-sent the ACC, and it was received by MRO on March 18,2021. G. Emissions Inventory. Submit an emissions inventory by June 30 of each year. Observed. The facility submitted their 2020 emission inventory on February 26, 2021. H. Refrigerant Requirements (Stratospheric Ozone and Climate Protection). Dispose of refrigerants properly. Observed. The facility uses a certified outside contractor for maintenance on refrigeration equipment. Royale Comfort Seating,Inc. -Plant No. 1 July 7, 2021 Page 6 1. Section 112(r). 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. 5. The following non-permitted air emission sources and control devices were observed as follows: None. 6. Summary of changes needed to the current permit: None. 7. Compliance assistance offered duringthe he inspection: I told Mr. Looper that the facility's semiannual reports must contain the visible emission summary report, and I explained that the VOC emission calculations for the glue must be done with the worst- case assumption of 75% VOC. I also sent an email on July 12, 2021 with this same information contained. 8. Compliance determination: Based on my observations, this facility appeared to be in violation with the applicable air quality regulations at the time of the inspection for failure to record monthly visible emission observations. EJS: MRO File https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00089/INSPECT 20210707.docx