AQ_F_0200005_20190709_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Mitchell Gold Company
NC Facility ID 0200005
Inspection Report County/FIPS:Alexander/003
Date: 07/09/2019
Facility Data Permit Data
Mitchell Gold Company Permit 02815/R14
375 Sharpe Lane Issued 9/24/2014
Hiddenite,NC 28636 Expires 8/31/2022
Lat: 35d 54.0708m Long: 81d 5.0058m 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
Scott Watson Steve Bruton Steve Bruton MACT Part 63: Subpart JJ,Subpart ZZZZ
Finishing Supervisor Director of Director of
NSPS: Subpart Dc
[phone] Administration Administration
[phone] [phone]
Compliance Data
Comments:
Inspection Date 07/09/2019
Inspector's Name Sandra Sherer
Inspector's Signature Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: l� !— On-Site Inspection Result Compliance
Total Actual emissions in T``ONSIYE'AR:
TSP S02 NOX VOC CO PM10 *HAP
2013 0.1900 --- 0.3500 25.33 0.2800 0.1900 3152.38
2008 0.1700 -- 0.3400 29.17 0.2700 0.1700 2340.71
*Highest HAP Emitted in pounds
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

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Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation' Evaluation/Reinspection Investigation
Data Date submitted for initial review: 7/10/2019 _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 Planning,Next Inspection Date: 7/1/2021
Directions: Take I-77 north to I-40 West. Take exit 148 and go right. Make a right onto HWY 90 North.
Once in Hiddenite,take a right onto Sulphur Springs Road. Cross the railroad tracks and take an
immediate right onto Sharpe Road. The facility is on the left past the Hickory Springs plant. Since Mr.
Bruton is located at another plant, he has requested that DAQ call before leaving the office so he can
meet us at the permitted plant. Also, have him email Mr. Scott Watson the NSPS and prohibitory small
records so that you can view them during the inspection.
Safety Equipment: The facility does not require any PPE for individuals that are not actively spraying.
However, it is recommended that you bring safety glasses anyway.
Safety Issues: No issues noted.
Lat/Long Coordinates: The coordinates were last checked in August of 2018 and were accurate. However,
the site is currently down. The coordinates in IBEAM are accurate.
Email Contacts: I confirmed the e-mail contacts with Mr. Steve Bruton.No changes are required.
1. The purpose of this site visit was to conduct a routine air quality inspection. This facility
manufactures finished wood furniture and is subject to 40 CFR 63, Subpart JJ. Mr. Steve Bruton,
Director of Administration, and Mr. Scott Watson, Finishing Supervisor, accompanied me during
this inspection. This facility works one shift Monday through Thursday with variable work on
Friday and employs roughly 70 people.
2. Facility Contact Information:
The contact information in IBEAM was verified and no changes are needed.
3. Compliance history file review:
No violations have been issued to this facility in the last five years.

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4. Observations of permitted air emission sources and control devices:
a.
Emission Emission Source
Source ID Description '
ES-B 1 ,,No. 2 fuel oil/natural gas-fired boiler(25.2 million
(NSPS) 1Btu per hour maximum heat input)
Observed. The boiler was not operating during this inspection. It was manufactured by
Superior(Mfg. date 1999,25.2 million Btu per hour,fire tube,Model 6-5-1000 and Serial
No. 14099). The boiler provides steam for the drying ovens and comfort heat for the
building during the winter.
b.
Source In Coating Gun Spray Operator/ Lb VHAP/
ID Use? Applied Type Product applied lb Solids
ES- Yes tonerLp Dakota Lail/ 1.88
SB 1 B 1 ON01063
ES- washcoat Pat Justice/ 0.4578
SB2 Yes lst sealer HVLP L490500
ES- glaze Dustin Head/ 0.0232
SB3 Yes (exempt) HVLP D22N2549
ES- Tasha Drew/ 0.000
SB4 Yes 15`shade HVLP
S79N0492
ES- Yes 2❑d sealer HVLP Greg Lackey/ 0.4578
SB5 L490500
ES- Barry Johnson/ 0.4434
SB6 I'eS lacquer HVLP L42C0909
ES- No N/A N/A N/A N/A
SB7
ES- Lola Jenkins/ 0.4434
SB8 Yes lacquer HVLP L42C0909
ES-
HVLP David Riddle/ 0.2631
SB9 Yes toner Cup E28A0187
guns
Source ID In Use? Application Comments
Glue is purchased in 275 gallon totes
ES-GO Yes PVA based gluing and transferred to small bottles and
operation buckets. It is used for dowels, etc
throughout facility.

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Source ID In Use? Application Comments
The facility uses acetone for washoff.
ES-WTI Both tanks were observed with lids
and ES- No washoff tank closed during the inspection. Only one
WT2 is ever used for washoff and the other
one is used for storage.
ES-1301 No steam-heated drying oven Ovens only operate with steam in the
winter when it is too cool to air dry
ES-D02 No steam-heated drying oven parts.It is also used to circulate air in
the summer.
Observed. All booths have dry filters and all filters were in place and appeared to be
properly maintained. All the booths are online, except for EB-9 which is located in an
enclosed booth with filters on all sides due to the location in a different area of the plant.
The clear finishes are pumped from the pump room while all others are in pressure pots at
the booth where they are used. No open containers were noted in the finishing room or
pump room areas.
5. Observations of insignificant air emission sources and control devices listed on the current permit:
a. IES-1 - diesel-fired pump (220 hp) for the fire suppression system (subject to NESHAP,
Subpart ZZZZ)
Observed. The Cummins generator is operated approximately 30 min/week to ensure it is
in good working order. The engine is considered an existing engine,therefore is subject to
NESHAP, Subpart ZZZZ. The generator has a non-resettable meter,which was at 412.58
hours during the inspection. It is a Model DC-23 with a Serial No. 6721.
6. Observations of air emission sources and control devices not listed on the current permit:
a. The facility has two cyclones on the roof that can be seen from the parking lot. There is
also a cyclone and a bagfilter located toward the back of the roof that are not as evident
from the parking lot. None of them are used and the ductwork going to them has been
removed. The facility does not do any woodworking that vents to the outside atmosphere.
b. The facility has a 600 gallon gasoline tank that needs to be added to the insignificant air
emission sources.
7. Compliance with specific permit conditions and limitations:
a. Condition A.2. requires the facility to submit the permit renewal application including
emission inventory at least 90 days prior to the expiration date of the air permit.
Observed. A new air permit was issued on September 30, 2014 due to expire on August
31,2022. Compliance is indicated.

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b. Condition A.3. — 15A NCAC 2D".0503 "Particulates from Fuel Burning Indirect Heat
Exchangers". Particulate matter emissions from the boiler(ID No.ES-B 1)shall not exceed
0.472 pounds per million Btu.
Observed. The facility only uses natural gas in the boiler, therefore remains well below
the 0.472 pounds per million Btu limit.
C. Condition AA — 15A NCAC 2D .0512 "Particulates from Wood Products Finishing
Plants". Provide adequate ductwork and properly designed collectors to control
woodworking and finishing particulates.
Observed. No particulate emissions were observed from the spray booths and the filters
appear to be properly maintained. Compliance with this stipulation is indicated.
d. Condition A.5. - 15A NCAC 2D .0516 "Sulfur Dioxide Emissions from Combustion
Sources,"sulfur dioxide emissions from boiler(ID No.ES-B 1)shall not exceed 2.3 pounds
per million Btu heat input.
Observed. The facility only uses natural gas in the boiler, therefore remains well below
the 2.3 pounds per million Btu limit.
e. Condition A.6. and A.7. - 15A NCAC'2D .0521, "Control of Visible Emissions". The
visible emissions from spray booths (ID Nos. ES-SB5, ES-SB8, ES-SB9), drying ovens
(ID Nos. ES-D02 and ES-DO 1), boiler (ID No ES-B1), washoff tank (ID No. ES-WT2)
and gluing operation(ID No. ES-GO) are limited to no more than 20 percent opacity.
The visible emissions from spray booths(ID Nos.ES-SB 1,ES-SB2,ES-SB3,ES-SB4,ES-
S136 and ES-S137), and washoff tank (ID No. ES-WTI) are limited to no more than 40
percent opacity.
Observed. No visible emissions were observed at the facility. Compliance with this
stipulation is indicated.
f. Condition A.8. - 15A NCAC 2D .0524, "New Source Performance Standards" (NSPS) as
promulgated in 40 CFR 60, Subpart Dc. Sulfur content of the distillate oil combusted in an
affected source shall not exceed 0.5 percent by weight. The company must demonstrate
compliance with NSPS Subpart Dc by reporting semi-annually the sulfur content of the
fuel combusted during the reporting period. This may be done by submitting fuel supplier
certifications. In addition, records of the amount of each fuel combusted must be
maintained on site for each month's fuel usage.
Observed. The facility is maintaining the monthly records as required. The last reports
were received on July 12, 2018 and January 14, 2019. The facility stated in both reports
that they did not burn any No. 2 fuel oil. The facility has a fuel oil storage tank onsite but
is not hooked up to the boiler and is empty. Compliance with this stipulation is indicated.
g. Condition A.9. 15A NCAC 2D .0535. The 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

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July 9,2019
Page 6
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. Bruton, no excess
emissions have occurred at the facility in several years. Compliance with this stipulation
is indicated.
h. Condition A.10. "Fugitive Dust Control Requirement" as required by 15A NCAC 2D
.0540 "Particulates from Fugitive Dust Emissions Sources:' states that 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. MRO DAQ has not received any fugitive dust emissions complaints
regarding this facility. During the inspection,I observed no fugitive dust or visible
emissions from this facility. Compliance with this stipulation is indicated.
i. Condition A.11. The wood furniture manufacturing operations spray booths (ID Nos.ES-
SB 1 through ES-SB9), drying ovens (ID Nos. ES-DO1 and ES-D02), washoff tanks (ID
No.ES-WT1 and ES-WT2), and gluing operation(ID No.ES-GO) are subject to the work
practice and emission limit requirements of the Wood Furniture MACT,NESHAP Subpart
JJ as promulgated in the Federal Register, 40 CFR Part 63 Subpart JJ, December 7, 1995.
Below is a synopsis of the compliance status with the Wood Furniture NESHAP
i. 40 CFR 63.802 "Emission limits"and
40 CFR 63.804 "Compliance Procedures and monitoring requirements"
The facility is subject to the following emission limits for existing sources:
SUMMARY OF EMISSION LIMITS
Emission Point Existing
Source
Finishing Operations
(a)Achieve a weighted average VHAP content across all coatings 1.0a
(maximum kg VHAP/kg solids [lb VHAP/lb solids], as applied)
OR
(b)Use compliant finishing materials
(maximum kg VHAP/kg solids [lb VHAP/lb solids], as applied):
-stains 1.0a
-washcoats 1.Oab
-sealers 1.0a
-topcoats 1.0a
-basecoats 1.Oab
-enamels 1.Oab
-thinners maximum%HAP allowable 10.0

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Emission Point Existing
Source
OR
(c)Use a combination of(a) and(b) 1.0
Cleaning Operations
Strippable spray booth material 0.8
(maximum VOC content, kg VOC/kg solids [lb VOC/lb solids])
Formaldehyde requirements
Effective November 21,2014
(a) Achieve total free formaldehyde emissions across all finishing 400
operations, lb per rolling 12 month period, as applied
OR
(b) Use coatings only if they are low-formaldehyde coatings and 1.0°
contact adhesives
a The limits refer to the VHAP content of the coating, as applied.
b Washcoats,basecoats, and enamels must comply with the limits presented in this table if they are
purchased premade,that is, if they are not formulated on-site by thinning other finishing materials.
If they are formulated on-site, they must be formulated using compliant finishing materials, i.e.,
those that meet the limits specified in this table, and thinners containing no more than 3.0 percent
HAP by weight.
'The limits refer to the formaldehyde content by weight of the coating or contact adhesive, as
specified on certified product data sheets.
This facility is permitted to use both the Compliant Coating and Averaging methods to
comply with the NESHAP. Compliance with each of these options is considered to be
a separate alternative compliance scenario and the facility must record in a logbook the
scenario under which it is operating. The facility is currently using the compliant
coating option.
The formaldehyde requirements became effective November 21, 2014. Per records,
the facility emitted 2.38 lbs of formaldehyde in 2018,which is well below the limits.
ii. 40 CFR 63.803 "Work Practice Standards"
40 CFR 63.803(a)"Work Practice Implementation Plan"The facility is required to
develop and maintain a written work practice implementation plan which addresses the
work practice standards in 40 CFR 63.803(b)through (1)as outlined below.
Observed. , This WPIP was adapted from the plan developed by Bassett Furniture
Company. The facility maintains a copy of the WPIP onsite. It is only two pages, but

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Page 8
it seems to cover the required topics. Mr. Bruton stated that Mitchell Gold Company
is a member of the American Furniture Manufacturing Association(AFMA). Mr. has
a detailed plan they provide for their employees. Compliance is indicated.
40 CFR 63.803(b) "Operator Training Course" The facility is required to provide
specific MALT-compliant training for all new employees and all existing employees
within six months of the effective date of the MACT, if the employees are to be
involved in finishing, gluing, cleaning, and/or washoff operations. Additionally,
annual refresher training is required. The training program has been developed and a
copy presented at the inspection.
Observed. The training records for all of the employees spraying at the time of
inspection as well as a random selection of others were reviewed. The facility had all
of the training records. The facility did the facility-wide training for this year on July
8, 2019, and on July 10, 2018 for the previous year. Compliance is indicated.
40 CFR 63.803(c) "Inspection and Maintenance Plan" Leak inspections of all
equipment used to transfer or apply coatings, adhesives, and/or organic solvents are
required to be conducted by the facility on a monthly basis.The date,inspection results,
and repairs made must be documented as well as time frames required for repairs.
Observed. Leak inspections and maintenance records were available for viewing and
appeared to indicate compliance. The logs indicate that inspection frequency and time
frames for repair of leaks were within MACT requirements. The official inspections
are typically at the end of the month, but the facility documents all leaks noted during
the month. There were no obvious leaks noted in the finishing area or pump room
during this inspection. Compliance is indicated.
40 CFR 63.803(d) "Cleaning and Washoff Solvent Accounting System" The
facility is required to record the quantity and type of organic solvent used each month
for washoff and cleaning,the number of pieces washed off,the reason for the washoff,
and the quantity of spent washoff solvent generated each month and whether it is
recycled onsite or disposed offsite.
Observed. The facility uses acetone as their washoff material. This is an exempt
material. All other records were being maintained as required. North State
Environmental disposes of the spent solvent offsite. Compliance is indicated.
40 CFR 63.803(e) "Chemical Composition of Cleaning and Washoff Solvents"
Washoff solvent used at the facility cannot contain any of the pollutants listed in Table
4 of Subpart JJ.
Observed. The facility uses acetone exclusively as the washoff and line cleaning
solvent. This is a compliant solvent. Compliance is indicated.
40 CFR 63.803(f) "Spray Booth Cleaning" Compounds used for cleaning spray
booth components cannot contain more than 8.0% by weight VOC. If the facility is
using a strippable booth coat no more than 1.0 gallon of organic solvent may be used

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Page 9
to prepare each booth for the application of new booth coating. If the facility is using
a strippable boothcoat material, it cannot contain more than 0.8 lbs VOC/lb solids.
Observed. The facility is using RPM Wood Finishes Group, HC VOC White
Boothcoat M55W0009 (0.7841 lb VOC/lb solids). This is a compliant boothcoat.
40 CFR 63.803(g)"Storage Requirements"Normally closed containers must be used
for storing finishing, gluing, cleaning, and washoff materials.
Observed. All VHAPs were in normally closed containers. Compliance is indicated.
40 CFR 63.803(h) "Application Equipment Requirements" Conventional spray
guns were permissible under certain circumstances until November 21, 2014. There
are no longer any exemptions for sources not venting to control devices.
Observed. HPLV spray guns are used exclusively at this at this facility. Compliance
is indicated.
40 CFR 63.803(i)and 0)"Line Cleaning and Gun Cleaning"Organic solvents used
for line and spray gun cleaning at the facility must be collected in normally closed
containers.
Observed. The facility uses acetone, which does not contain any HAPs. No solvent
from lines or spray guns was being collected at the time of this inspection. Compliance
is indicated.
40 CFR 63.803(k) "Washoff Operations" Emissions from washoff operations shall
be controlled by using normally closed tanks and tilting or rotating parts to minimize
dripping.
Observed. Neither washoff tank was in use at the time of this inspection. Both were
closed. Compliance is indicated.
40 CFR 63.803(1) "Formulation Assessment Plan for Finishing Operations" The
facility must identify VHAPs from Table 5 of Subpart JJ that are being used at this
facility and establish a baseline based on the highest annual usage from 1994, 1995 or
1996. If the annual usage of these VHAPs exceeds the baseline level,the facility must
provide written notice to DAQ that describes the amount of the increase and the reason
for the exceedance of baseline levels.
Observed. The facility's baseline is considered the deminimus for all pollutants in
Table 5 since they were not operating in 1994, 1995, or 1996. Records of these
pollutants are kept as part of the prohibitory small recordkeeping. The only pollutant
that the facility is currently emitting that is on Table 5 is formaldehyde, which was
2.38 pounds in 2018. This is well below the 400 pound deminimus.

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Page 10
iii. 40 CFR 63.804 "Compliance Procedures and monitoring requirements"
40 CFR 63.804(a) The facility is required to choose a method of compliance to
demonstrate compliance with the above emission limits
(a)(2) This facility has chosen the compliant coatings approach with averaging as a
backup option to show compliance with the emission limitations. The facility is
required to maintain certified product data sheets for each coating and thinner.
Observed. All of the finishes being used at the time of inspection were checked and
all were compliant as shown in the table in section 4 above. A random selection of
other materials was also verified to be in compliance.
(g)(2) The facility is required to demonstrate continuous compliance by using
compliant coatings,maintaining certified product data sheets showing the coatings are
compliant,and submitting a compliance certification with the semiannual report which
states the facility used compliant coatings each day of the reporting period. See the
reporting requirements for 63.807 below.
Observed. The facility only uses compliant coatings and product data sheets were
made available for me to review during the inspection.
(g)(5) The facility is required to demonstrate continuous compliance by submitting a
compliance certification stating that compliant contact and/or foam adhesives were
used during each day of the semiannual reporting period. See the reporting
requirements for 63.807 below.
i
(g)(7) The facility is required to demonstrate continuous compliance by submitting a
compliance certification stating that compliant strippable spray booth coatings were
used during each day of the semiannual reporting period. See the reporting
requirements for 63.807 below.
(g)(8) The facility is required to demonstrate continuous compliance by submitting a
compliance certification stating that the work practice implementation plan was being
followed during each day of the semiannual reporting period. See the reporting
requirements for 63.807 below.
iv. 40 CFR 63.806 "Record keeping requirements"and
40 CFR 63.807 "Reporting requirements"
The facility is required to maintain records of each of the requirements above.
Additionally, the facility is required to submit semi-annual reports indicating
compliance with all appropriate sections of 40 CFR 63, Subpart JJ. These reports are
due 30 days after the end of each 6-month period.
Observed. The facility appears to be maintaining the required records. The latest
reports were received on July 12,2018 and January 14,2019. Based on the information
submitted,the reports appeared to indicate compliance.

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j. Condition A. 12. -Federal and State Rules Applicable to Sources Exempted from Air
Permitting Requirements-Your facility is subject to the following federal and state rules:
F40C1FR 63 -NESHAP/MACT-- Subpart ZZZZ--Reciprocatingal Combustion Engines
which are applicable to some of the emission sources at the facility listed on the
"Insignificant/Exempt Activities" list attached to the Air Permit.
Maintenance and Work Practices-Pursuant to 40 CFR 63.6603(a), 63.6625(e), (f), and
(h) and 63.6640(f)the Permittee shall comply with the following:
Change the oil and filter every 500 hours of operation or annually, whichever comes first.
The Permittee has the option to utilize an oil analysis program as described in Section c.
below in order to extend the specified oil change requirements.
ii. Inspect the air cleaner every 1,000 hours of operation or annually,whichever comes first,
and replace as necessary.
iii. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes
first, and replace as necessary.
iv. Operate and maintain the engine and control device(if any)according to the
manufacturer's emission related written instructions or maintenance plan developed by
the Permittee that minimizes emissions from the engine to the extent practicable.
V. Install a non-resettable hour meter if one is not already installed.
ti
vi. Minimize the engine's time spent at idle during startup and minimize the engine's startup
time to a period needed for appropriate and safe loading of the engine, not to exceed 30
minutes, after which time the non-startup emission limitations apply.
vii. If the engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the management practice requirements on the schedules
required in Sections b.i., b.ii., and b.iii., above, or if performing the management practice
on the required schedules would otherwise pose an unacceptable risk under federal, state
or local law,the management practices can be delayed until the emergency is over or the
unacceptable risk under federal, state, or local law has abated. The management practice
shall be performed as soon as possible after the emergency has ended or the unacceptable
risk has abated. The Permittee shall report any failure to perform the management
practice on the schedule required and the federal, state, or local law under which the risk
was deemed unacceptable.
viii. If the Permittee does not operate the engine according to the requirements in Sections A.
through C. below,then the engine will not be considered an emergency engine under
NESHAP Subpart ZZZZ and must meet all requirements for non-emergency engines.
A. There is no time limit on the use in emergency situations.

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B. The Permittee may operate the engine for any combination of the purposes
specified in Sections(i)through(iii)below for a maximum of 100 hours per
calendar year.
(i) The engine may be operated for maintenance checks and readiness
testing,provided that the tests are recommended by federal, state or local
government,the manufacturer,the vendor,the regional transmission
authority or equivalent balancing authority and transmission operator, or
the insurance company associated with the engine.
The Permittee may petition the Division of Air Quality(DAQ)Regional
Supervisor for approval of additional hours to be used for maintenance
checks and readiness testing,but a petition is not required if the
Permittee maintains records indicating that federal, state, or local
standards require maintenance and testing of the engine beyond 100
hours per calendar year.
(ii) The engine may operate for emergency demand response for periods in
which the Reliability Coordinator under the North American Electric
Reliability Corporation(NERC)Reliability Standard EOP-002-3,
Capacity and Energy Emergency or other authorized entity as determined
by the Reliability Coordinator has declared an Energy Emergency Alert
Level 2 as defined in the NERC Reliability Standard EOP—002-3.
(iii) The engine may be operated for periods where there is a deviation of
voltage or frequency of 5 percent or greater below standard voltage or
frequency.
C. Pursuant to 40 CFR 63.6640(f)(4),the engine may be operated for up to 50 hours
per calendar year in non-emergency situations.The 50 hours of operation in non-
emergency situations are counted as part of the 100 hours per calendar year for
maintenance and testing and emergency demand response provided in Section
b.viii.B above. Except as provided in Sections (i) and(ii)below,the 50 hours
per year for non-emergency situations cannot be used for peak shaving or non-
emergency demand response, or to generate income for the facility to supply
power to an electric grid or otherwise supply power as part of a financial
arrangement with another entity.
Observed. The diesel-fired pump (ID No. IES-1) is subject to 40 CFR Part 63 NESHAP,
Subpart ZZZZ for Stationary Reciprocating Internal Combustion Engines(referred to as
RICE NESHAP). This engine is an existing emergency unit.
The facility records all usage in a logbook with the corresponding start and stop hour
meter readings. The generator has a non-resettable hour meter which read 412.58 hours
during this inspection compared to 3 82.10 during the last inspection on August 17,2017.
Oil changes and maintenance performed since the last inspection were conducted on
December 6, 2017, December 7,2018 and January 25,2019. Compliance is indicated.

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k. Condition A. 13.The AVOIDANCE CONDITION FOR AREA SOURCES SUBJECT TO
40 CFR 63 Subpart JJJJJJ (Q). The Permittee is avoiding applicability of 40 CFR 63
Subpart 6J for the boiler(ID No. ES-B1). This source is exempt from this Subpart since it
is defined as a gas-fired boiler because it only burns fuel oil during periods of gas
curtailment or for periodic testing on liquid fuel. The Permittee shall maintain records that
document the time periods when liquid fuel is fired and the reasons the liquid fuel is fired.
They must also provide notification if they no longer become exempt from this regulation.
Observed. The facility already maintains fuel usage as required by NSPS, Subpart Dc.
They are only burning natural gas at this time. Compliance is indicated.
1. Condition A.14. 2Q .0803 "Coating, Solvent Cleaning and Graphic Arts". The facility
potential emissions (defined as actual emissions)are limited to-100 tons per year VOC, 10
tons per year of each individual HAP and 25 tons per year of all HAPs combined. The
Facility is required to submit an annual report by March 1 of each year containing a
summary of the referenced emissions.
Observed. Steve Bruton maintains records of VOC and HAP emissions. The records are
kept at the main plant. They only have records of the emissions per an annual report from
the supplier, but they keep daily records of the usage of each product to verify
compliance at any time.
The Mooresville Regional Office received the required annual report on February 15,
2019. It indicated that the facility had emitted 13.59 tons VOCs, 1.19 tons total HAPs,
and 0.75 tons highest HAP(toluene)in 2018. The report indicated compliance with the
permit limits.
8. NSPS/NESHAP Review:
This facility is currently subject to the Wood Furniture NEHSAP, Subpart JJ. All records were
checked during the inspection and the facility appeared to be in compliance with all of the
requirements of the NESHAP.
The facility is not subject to the Flexible Polyurethane Foam Production and Fabrication NESHAP
Subpart 60.
The exempt diesel-fired pump (IES-1) for the fire suppression system is subject to NESHAP
Subpart 4Z.
The facility has elected to take the NESHAP Subpart 6J avoidance option by only using No. 2 fuel
oil in times of curtailment in the boiler(ES-B 1).
The facility is subject to NESHAP Subpart 6C for the 600 gallon gasoline tank on site. However,
the tank is empty and has not been used since they moved into the building in 2005.

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9. Summary of changes needed to the current permit:
The 600 gallon gasoline tank needs to be added to the yellowsheet as an insignificant emission
source.
10. Compliance assistance offered during the inspection:
None.
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.
SLS:Ihe
c: MRO File
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