AQ_F_0200089_20200310_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Royale Comfort Seating,Inc.-Plant No. I
NC Facility ID 0200089
Inspection Report County/FIPS:Alexander/003
Date: 03/10/2020
Facility Data Permit Data
Royale Comfort Seating,Inc.-Plant No. I 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
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 03/10/2020
Inspector's Name Melinda Wolanin
Inspector's Signature: 1, Operating Status Operating
At4, (,l�(,t, ��1:� Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: 3 —1 2 Z 0 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2018 -- --- --- 26.20 --- --- 48360.00
2017 --- --- --- 15.20 --- 28005.00
2016 --- 13.80 26202.00
*_ Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
03/1 2120 1 9 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
March 10,2020
Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Tracking: Date submitted for initial review 03/I I/2020 _IBEAM WARNING/OB,NOD,NOV,or 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 03/01/2021
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/Lone Coordinates: The latitude and longitude coordinates of this facility are correct and locked in
IBEAM and appear correct on the DAQ facility mapping tool on the DAQ website.
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.
The inspector arrived at the facility around 10:30 am on March 10, 2020. This facility cuts and
glues foam for chair cushions. The facility is currently operating forty hours per week. Mr. Lee
Isenhour, HR and Safety 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/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
March 10,2020
Page 3
The facility was issued an NOV on March 12,2019 for late submission of their annual
compliance certification (ACC)
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:
Foam Fabrication Process consisting of Glue Spraying Operation (ID No. ES-2)
Observed. The facility operates glue stations with sixteen HVLP glue guns. Nine 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 on the amount of adhesive used in gallons. They used
around 6063 gallons of material in 2019. There is a small amount of solids (less than 0.1
lb/gal) contained in the adhesive (559 Ibs/yr of solids). The facility is well under the
allowable emission rate. Compliance is indicated.
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.

Royale Comfort Seating, Inc.-Plant No. I
March 10,2020
Page 4
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.
They are keeping monthly visible emissions logs, which I observed from March 2019 through
February 2020. The most recent observation was conducted on February 12, 2020. Summary
reports were received on July 30, 2020 and January 29, 2020 with compliance indicated.
Compliance for this condition is indicated.
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: AVOIDANCE CONDITION
for 15A NCAC 02D .0530: PREVENTION OF SIGNIFICANT DETERIORATION
In order to avoid applicability of this regulation,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).
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. I observed the monthly VOC calculations based on material used through
February 2020. The most recent report was received on January 29, 2020 with compliance
indicated. Compliance with this condition is indicated.
4. Part I - AIR QUALITY TITLE V OPERATION PERMIT. Section 3 - GENERAL
CONDITIONS

Royale Comfort Seating, Inc. -Plant No. I
March 10,2020
Page 5
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 received a Notice of Violation dated
March 12, 2019 for failure to submit their CY 2018 ACC on time. The report was
received March 18, 2019.The ACC for CY 2019 was received January 29, 2020.
G. Emissions Inventory. Submit an emissions inventory by June 30 of each year. Observed.
The facility submitted their 2019 emission inventory on February 25,2020.
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.
I. 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:
1 bandsaw that cuts the foam blocks into long strips and hand saws that then cut forms out of the
strips.
1 fluffer machine that separates clumps of polyester fill with blown air and then blows the fill to
the stuffing room.
6. Summary of changes needed to the current permit:
Mr. Isenhour indicated that the facility was not continuing the use of the carbon filters mentioned
during the previous inspection.The yellowsheet was updated.

Royale Comfort Seating, Inc. -Plant No. 1
March 10, 2020
Page 6
7. Compliance assistance offered during the inspection:
The deviation summary report for the ACC for CY 2019 needed more information, so I indicated
to Mr. Isenhour what additional information was necessary and let him know that he would need
to resubmit the deviation summary to both DAQ MRO and EPA Region 4.
8. 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.
MJW:Ihe
c: MRO File
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