AQ_F_1800011_20210729_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Bassett Upholstery Division
NC Facility ID 1800011
Inspection Report County/FIPS: Catawba/035
Date: 07/29/2021
Facility Data Permit Data
Bassett Upholstery Division Permit 03981 /R15
1111 East 20th Street Issued 8/10/2016
Newton,NC 28658 Expires 7/31/2024
Lat: 35d 40.9510m Long: 8ld 12.3960m Class/Status Synthetic Minor
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
Theodore Lewis Mike Kreidler Theodore Lewis MACT Part 63: Subpart 6J,Subpart 60
Assistant Maintenance VP of Upholstery Assistant Maintenance NSPS: Subpart Dc
Supervisor [phone] Supervisor
[phone] [phone]
Compliance Data
Comments:
Inspection Date 07/29/2021
Inspector's Name Emily Supple
Inspector's Signature: &n4 J�/ Su pp& 09A Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: 8/16/2021 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2015 3.75 0.2200 4.11 44.08 4.98 2.82 9537.60
2010 5.27 2.97 4.54 24.14 4.47 2.17 5727.68
*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

Bassett Upholstery Division
July 29,2021
Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review: 8/11/2021 _IBEAM WARNING/OB,NOD,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 Next Inspection Date: 7/01/2022
Directions: From MRO,take Hwy. 150 West,turn right onto Hwy. 16 North through Newton,turn right onto College
Rd. (turns into Main St.). Turn right onto 201}i Street. The Facility is located on the right at Burris Road.
Safety Equipment: Safety glasses and safety shoes are recommended.
Safety Issues: When inspecting the spray booths,beware of moving parts on overhead conveyor system.
Lat/Long Coordinates: A review of the facility's coordinates on"Maps of DAQ Regulated Facilities"indicated
the facility's latitude and longitude coordinates were accurate and locked within IBEAM.
Email Addresses: The email addresses for the contacts in IBEAM were verified,and no changes are required.
1. The purpose of this site visit was to conduct a routine air quality inspection. The facility operates two nine hour
shifts per day, four to five days per week. This facility manufactures upholstered furniture. The facility is
currently operating eight (8) routers 8-10 hours per day, 5 days per week. The plant shuts down for the week of
the 4' of July holiday and for 2 days during Christmas. I arrived at the facility at about 10:45 AM on July 29,
2021. Mr. Ted Lewis,Assistant Maintenance supervisor, accompanied me during this inspection.
2. Facility Contact Information:
During the inspection,I verified the facility contact information in IBEAM. No changes are needed at this time.
3. Compliance history file review:
An NOV/NRE was issued to the facility on April 14, 2013 for failed stack test conducted on December 12, 2012.
The facility was assessed $2,265, which was paid in full on June 24, 2013. The facility re-tested on November
12,2013 and demonstrated compliance.
4. Observations of permitted air emission sources and control devices:
Emission Emission Source F Control Control System
Source ID Description System ID Description
Furniture Finishing Operation(ID No.F-1)
ES-SB-5,ES- five (5)dry filter-
SB-6,ES-SB-7,ES- type paint spray N/A N/A
SB-8,ES-SB-9 booths

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Emission Emission Source Control Control System
Source ID Description System ID Description
Observed. The booths were not in operation during the inspection. Mr. Lewis stated that the filters are
changed out on a weekly basis or as needed.
ES-SB-1,ES- four(4)baffle
SB-2,ES-SB-3,ES- filter-type paint FN/A N/A
SB-4 spray booths
Observed. These booths are now dry filter-type paint spray booths. The booths were not in operation at the
time of inspection. The filters on these booths are also changed out on a weekly basis or as needed. Mr.
Lewis indicated that one of the booths is to be replaced with a larger dry filter-type spray booth.
ES-T-1 wash-off tank I N/A I N/A
Observed. The wash-off tank was not in use during the inspection and was covered with a lid.
ES-LD-I furniture leg N/A N/A
dipping operation
Observed. This operation is not being used by the facility at this time.
ES-G-1 Fi�;
ng operations N/A N/A
(NESHAP)
Observed. The gluing operation was in operation during the inspection with no odorous emissions.
Woodworking Operations
ES-W-I woodworking CD-C-3, CD-F-1, cyclone(CD-C-3, 80 inches in diameter)
operation#1 CD-F-4, CD-F-2 installed in parallel with a bagfilter(CD-F-
2, 3,873 square feet of filter area)that is
installed in parallel with two other
bagfilters (ID No. CD-F-1; 1,340 square
feet of filter area)and(ID No. CD-F-4;
1,155 square feet of filter area)
Observed. This woodworking operation is housed in building#2 and consists of a wood hog and eleven
routers. CD-F-1 is not being used. CD-C-3 is used in series with CD-F-4 to control wood waste from the
wood hog. Another cyclone not listed on the permit is used in series with CD-F-2 to control waste from the
routers. There is also an enclosed trailer which collects wood dust from the silo. I observed the wood hog
and two routers operating during the inspection with no visible emissions.
ES-W-5 woodworking CD-C-1 simple cyclone (156 inches in diameter)
operation#5
Observed. Woodworking operation#5 has been taken out of service.
ES-W-6 Farea
ple production CD-C-2 simple cyclone (60 inches in diameter)
Observed. This woodworking operation is housed in building#1 and is considered the R&D area. There is
a router,planer and some saws in this area that were not in operation at the time of the inspection.
Boilers
ES-B-2 coal/wood fuel-fired CD-2 multi-cyclone(18 nine-inch diameter
(NESHAP) boiler(36 million tubes)
Btu per hour
maximum heat

Bassett Upholstery Division
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Emission Emission Source F Control Control System
Source ID Description System ID Description
input)
Observed. This source is in building#2 and was not operating at the time of the inspection. Wood is the
only fuel that is currently being used.
ES-B-3 (NSPS, natural gas/No. 2
NESHAP) fuel oil-fired boiler
(38.64 million Btu N/A N/A
per hour maximum
Peat input)
Observed. This source was not operational at the time of the inspection and has not been used since
February 2020. Although they are permitted to burn both natural gas and No. 2 fuel oil,they do not
currently store No. 2 fuel oil for the boiler and the boiler does not have a connection for using No. 2 fuel. If
the facility ever starts to burn No. 2 fuel oil,they must begin to comply with the new opacity requirements
under NSPS Subpart Dc.
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-ES-O-1 -natural gas-fired paint cure oven(1.5 2Q .0 Yes
102 yes
million Btu per hour maximum heat input rate) (h)(1)(B)
Observed.The oven was not in operation during the inspection.
I-ES-0-2 -natural gas-fired shrink wrap oven 2Q .0102
(3.0 million Btu per hour maximum heat input (h)(1)(B) Yes Yes
rate)
Observed.The oven was not in operation during the inspection.
I-TANK1 —diesel fuel storage tank(1,000 2Q .0102 (g)(4) F No No
gallons capacity)
Observed. Did not observe the tank being loaded or unloaded during the inspection.
I-TANK2 -waste oil storage tank(500 gallons [2Q 0102 (g)(4) No No
capacity)
Observed. Did not observe the tank being loaded or unloaded during the inspection.
I-TANK3 -gasoline storage tank(500 gallons [2Q .0102 (g)(4) F No No
capacity)
Observed. This tank has been disconnected and is not in use at this time.
I-TANK4 -fuel oil storage tank(250 gallons [2Q .0102 (g)(4) No No
capacity)
Observed. Did not observe the tank being loaded or unloaded during the inspection.
�I-SILO -wood storage silo with bin vent(CD- [2Q .0102 (h)(5) F No Yes
F-3, 54 square feet of filter area)
Observed. The silo was processing wood dust which was sent to an enclosed trailer for sale during

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Page 5
the inspection with low visible emissions(about 5%opacity).
6. Observations of air emission sources and control devices not listed on the current permit:
An enclosed trailer which collects wood dust from the silo and appears to be an insignificant source.
A cyclone, 96 inches in diameter,on building#2, installed in series with CD-F-2
7. Compliance with specific permit conditions and limitations:
1. Condition A.3. 15A NCAC 2D .0503 "Particulate from Fuel Burning Indirect Heat Exchangers" limits the
facility's coal/wood and natural gas/No. 2 fuel-fired boilers to allowable emissions rates as detailed in the
permit.
Observed. The facility no longer combusts coal in the boiler(ID No. ES-B-2) and combusts only natural
gas fuel in the boiler(ID No. ES-13-3). Compliance is demonstrated in the last permit review.
2. Condition AA 15A NCAC 2D .0504 "Particulate from Wood Burning Indirect Heat Exchangers" limits
the facilities coal/wood is allowable emissions rates as detailed in the permit.
Observed. The boiler (ID No. ES-B-2) was not operating during the inspection. The boiler is being
operated at the manufacturer's designed rate, which was included in the permit review. Compliance is
demonstrated in the last permit review.
3. Condition A.5. 15A NCAC 2D .0512 "Particulates from Wood Products Finishing Plants". Provide
adequate duct work and properly designed collectors to control woodworking particulates.
Observed. The facility appeared to have adequate duct work, and the bagfilters and cyclones appeared to
provide sufficient control for their woodworking operations. They also have dry filters and baffles in
their spray booths. Compliance is demonstrated.
4. Condition AA 15A NCAC 2D .0516, "Sulfur Dioxide Control Requirement". The permittee is required
to limit sulfur dioxide emissions from combusted fuel to 2.3 pounds per million Btu heat input.
Observed. This requirement was evaluated during the permit review process and the facility was found
to be in compliance.
5. Conditions A.7 and A.8. 15A NCAC 2D .0521, "Control of Visible Emissions". The facility is limited to
20 percent opacity for paint spray booths ID Nos. ES-SB-7, ES-SB-8, ES-SB-9; sample production area
ID No. ES-W-6; woodworking operation ID No. ES-W-1;boiler ID No. ES-B-3; gluing operations ES-G-
1 and leg dipping operation ID No. ES-LD-1. The facility is limited to 40 percent opacity for paint spray
booths ID Nos. ES-SB-1 through ES-SB-6; wash-off tank ID No. ES-T-1; boiler ID No. ES-B-2 and
woodworking operation ID No. ES-W-5.
Observed. The woodworking equipment was in operation at the time of inspection with low visible
emissions from the silo and enclosed trailer. The facility properly maintains the equipment and changes
filter paper weekly on the paint spray booths. The coal/wood fuel-fired boiler(ES-B-2)was not operating
at the time of inspection. Compliance is demonstrated.

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6. Condition A.9. 15A NCAC 2D .0524 "New Source Performance Standards". The natural gas/No. 2 oil-
fired boiler (ID No. ES-B-3) is subject to NSPS Dc requirements. The facility is required to submit fuel
type at the time of start-up notification. The facility is required to test the boiler using the fuel reported to
DAQ for visible emissions. Subsequent to initial testing, the facility can perform periodic opacity
monitoring or develop a site-specific monitoring plan requiring DAQ approval. The facility needs to
keep monthly records of the fuel type combusted and quantities used. Records must be maintained for
two years. The facility must submit a semi-annual report after start-up of No. 2 fuel oil.
Observed. The boiler is currently not operational but historically, has not combusted No. 2 fuel oil. The
boiler only uses natural gas, and they have already submitted the required notifications for the natural gas.
Since a start-up notification should be submitted for each fuel type,the facility must also submit a start-up
notification when they decide to use No. 2 fuel oil. This includes an initial Method 9 test and periodic
Method 9 monitoring. The facility must also keep monthly records of each fuel combusted. The facility
is maintaining the required records of the natural gas combusted; therefore, they are in compliance with
the recordkeeping requirements.
7. Condition A.10. 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. Lewis, no excess emissions have
occurred at the facility since the last inspection. Compliance with this condition is indicated.
8. Condition A.11. 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources". The facility
must not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess
visible emissions beyond the property boundary.
Observed. There have not been any dust complaints received for this facility. There was no dust
observed beyond the property boundary. Compliance is demonstrated.
9. Condition A.12. 15A NCAC 2D .0958: "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. No spills or source issues were observed. Compliance with this stipulation is indicated. This
stipulation is no longer required in the permit due to the facility not being in the region of concern and
should be removed at the next open permit.
10. Condition A.13. 40 CFR 63, Subpart 000000, "National Emission Standards for Hazardous Air
Pollutants for Flexible Polyurethane Foam Production and Fabrication Area Sources". The gluing
operation (ES-G-1) is subject to this Rule, which states that the facility cannot use any adhesive
containing methylene chloride.
Observed. The facility no longer uses adhesives that contain methylene chloride. They keep MSDS on
site of the adhesives used. Compliance is demonstrated.
11. Condition A.14. 40 CFR 63, Subpart JJJJJJ, " National Emission Standards for Hazardous Air Pollutants
for Area Sources: Industrial, Commercial, and Institutional Boilers". Both Boilers (ES-B-2 and ES-B-3)
are subject to this Rule. The facility must demonstrate compliance with the initial tune-up requirements

Bassett Upholstery Division
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Page 7
by March 21, 2012 and repeated within 25 months. They must comply with energy assessment
requirements by March 21, 2014. Initial Notification is required by September 17, 2011. Notification of
Compliance Status is required by July 19, 2012. If the compliance status notification for the energy
assessment is not included in the July 19, 2012 notification, a separate notification for this requirement is
required by July 19,2014. A biennial compliance report must be prepared by March 1 of every other year
starting March 1,2015 and submitted upon request,unless the source experiences any deviations from the
applicable requirements then the report must be submitted by March 15.
Observed. The facility conducted the initial boiler tune-ups on March 8, 2012 and completed a
combustion analysis on October 23,2012. The energy assessment was completed December 9,2013. The
NOCS was submitted in CEDRI on July 14, 2014. The facility previously conducted biennial tune-ups on
boiler (ES-B-2) on July 9, 2014, August 31, 2016 and August 4, 2017. The next biennial tune-up on
boiler (ES-B-2) was not due until September 4, 2019. The facility completed this tune-up on April 17,
2019. The next tune-up would have been due on May 17, 2021. However, this boiler is not currently
operational and Mr. Lewis indicated that it has not operated since February 2020. Thus, the facility has
not yet completed this tune-up. The facility maintains records of usage and can show boiler (ES-B-3) is
only run 2-3 days per month during a five-month period of the year making it a limited use boiler. Since
the boiler is considered limited use, the facility is only required to conduct a tune-up every five years.
The previous tune-up on boiler(ES-B-3)was conducted on July 9, 2014, so the next tune-up was not due
until August 9, 2019. The facility completed this tune-up on April 17, 2019, so the next tune-up will be
due on May 17, 2024. Copies of all notifications, tune-ups, and the energy assessment are being
maintained on-site for review by the inspector. Compliance with this stipulation is indicated.
12. Condition A.15. 15A NCAC 2Q .0501 "Synthetic Minor Facilities." To ensure that the facility-wide
emissions do not exceed the permit limits, the facility is required to maintain fuel certification records of
fuel combusted to verify that the sulfur content limit is not exceeded(less than 1.0 percent by weight for
coal). The facility is required to maintain monthly records of the type and amount of fuel combusted in
the boilers as well as a monthly facility-wide emissions log for PM-10, S02, NOx, CO, VOC's, total
HAPs and individual HAP. The facility is also required to submit an annual report within 30 days after
each calendar year detailing the monthly and annual emissions of PM-10, S02, NOx, CO, VOCs, HAPs
and individual HAP for the previous 12 months,and copies of the fuel certification records. They are also
required to conduct an annual inspection of bagfilter & cyclone units. The bagfilter inspection must be
conducted internally.
Observed. The facility is maintaining monthly records of fuel combustion and facility-wide emissions.
The inspections of the bagfilter & cyclone systems and logbooks were properly maintained. The control
device inspections are conducted more frequently than annually. The most recent internal inspections of
the bagfilter and cyclones systems were conducted on February 8, 2019, December 20, 2019 and
November 4, 2020. The most recent internal inspections of the multi-cyclone were conducted on June 3,
2019, May 21, 2020, and April 22, 2021. The annual report for calendar year 2020 was received by this
office on January 19,2021,indicating compliance with the permit limits. Compliance is indicated.
13. Condition A.16. 15A NCAC 2D .0530 "Prevention of Significant Deterioration". Sulfur Dioxide
emissions are limited to 250 tons per year. There are no additional recordkeeping or reporting
requirements under this condition, since the Synthetic Minor requirements are sufficient for
demonstrating compliance.
Observed. The facility emitted 0.08 tons of S02 in 2020. Compliance is indicated.

Bassett Upholstery Division
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14. Condition A.17. 15A NCAC 2Q .0711, "Emission Rates Requiring a Permit". The facility must
comply with the following limits:
Chronic Acute Acute
Pollutant Carcinogens Toxicants Systemic Irritants
(lb/yr) (lb/day) Toxicants (lb/hr)
(lb/hr)
Ethyl acetate(141-78-6) F 147.41
MEK(methyl ethyl ketone,2-butanone)(78- 155.8 793-19
93-3)
MIBK(methyl isobutyl ketone)(108-10-1) 107.8 31.59
Toluene (108-88-3) 197.96 58.97
Xylene(mixed isomers)(1330-20-7) 113.7 F 68.44
Observed. The facility is maintaining product usage records to ensure that the above limits are
not exceeded. The facility's highest emitting TAP is toluene. The facility emitted 2,933 lbs. of
toluene in 2020,remaining below their emission limits. Compliance is demonstrated.
8. NSPS/NESHAP Review
The foam gluing activities are subject to the NESHAP Subpart 60. This facility is not subject to the
furniture MACT, Subpart JJ, since the facility is not a major source of HAPs. The two existing boilers
(ES-B-2 and ES-B-3) are subject to the Boiler NESHAP Subpart 6J. There are no generators at the
facility and the fire-pump on site is electric, therefore the facility is not subject to NESHAP Subpart 4Z.
The facility has a gasoline tank that has been disconnected, therefore is not subject to NESHAP Subpart
6C.
9. Summary of changes needed to the current permit:
ES-W-5 is not being used and may be removed the permit.
CD-F-1 is not being used and may be removed from the permit.
Add an enclosed trailer to building#2 to insignificant source list. The trailer collects wood dust from the
silo. The wood dust is then sold to other businesses.
Add a 2"d cyclone, 96 inches in diameter,to building#2, installed in series with CD-F-2.
Change description of control system for ES-W-1 to"cyclone(CD-C-3, 80 inches in diameter) installed
in series with a bagfilter(ID No. CD-F-4; 1,155 square feet of filter area), cyclone(CD-xxxx, 96 inches
in diameter)installed in series with a bagfilter(ID No. CD-F-2; 3,873 square feet of filter area)". There
are two control loops,both of which vent to the silo. The first loop consists of the wood hog which is
vented to cyclone CD-C-3 which exhausts to the silo and to bagfilter CD-F-4. The exhaust from CD-F-4
vents back into the silo. The second loop consists of the routers which are vented to the 96-inch cyclone

Bassett Upholstery Division
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Page 9
which exhausts to the silo and to bagfilter CD-F-2. The exhaust from CD-F-2 vents back into the silo. The
silo then vents to the enclosed trailer where the wood dust is collected and sold.
10. Compliance assistance offered duringtpection:
Mr. Lewis indicated that the facility is planning to swap out one of the old paint spray booths for a new larger
one. I indicated that the facility should submit this information to MRO such that a permit applicability
determination can be performed as necessary.
11. Section 112(r) gpplicability:
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.
EJS:
cc: MRO File
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