AQ_F_0200068_20191121_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: 11/21/2019
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
Jonathan Foster Tom Dunston Eric Houston MACT Part 63: Subpart 6J,Subpart 60
Plant Manager Division Manager Environmental
[phone] [phone] Coordinator
[phone]
Compliance Data
Comments:
Inspection Date 11/21/2019
--- Inspector's Name Ryan Mills
Inspector's Signature: �p Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: �Z/3 On-Site 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 inpounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

Carpenter Company-Taylorsville Plant
November 21, 2019
Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Tracking: Date submitted for initial review 11/26/2019 _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 1.1/01/2021
Directions:
From MR0,travel I-77 North,take 1-40 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 facility's coordinates on the updated DEQ website, "Facilities Regulated by Air Quality"
indicated the facility's latitude and longitude coordinates are accurate.
Email Contacts:
The email addresses were checked and appear to be accurate.No changes needed.
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 40 hours a week. The facility currently employs
approximately 63 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. The facility contact
was updated to Mr. Foster.
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

Carpenter Company-Taylorsville Plant
November 21,2019
Page 3
4. Observations of permitted air emission sources and control devices:
Emission Emission 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 9 spray guns.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 125 to 150 gallons of glue per week.
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 r Exemption Regulation
rIES 1 —No. 2 fuel oil-fired boiler(5.23 million Btu/hour maximum heat 2Q .0102(c)(2)(B)(i)(I)
put) 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: The report is not due at this time. Compliance with this condition is
indicated.

Carpenter Company-Taylorsville Plant
November 21, 2019
Page 4
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: All fifty-five-gallon drums of glue were properly closed. No spills were
observed. The facility has a satisfactory system to drain solvents used to clean supply
lines and other coating equipment into closable containers and close containers
immediately after each use.Mixing and blending vats and containers are cleaned by
adding cleaning solvent, closing the vat, or container before agitating the cleaning
solvent. Compliance with this condition is indicated.
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 January 2, 2019)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
"Insignificant/Exempt Activities" list attached to this permit.

Carpenter Company-Taylorsville Plant
November 21,2019
Page 5
40 CFR 63 -NESHAPIGACT--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.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 71 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)
9. Summary of changes needed to the current permit:
None.
10. Compliance assistance offered duringthe he inspection:
None needed 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:lhe
c: MRO File
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