AQ_F_1800580_20181127_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Elite Comfort Solutions
NC Facility ID 1800580
Inspection Report County/FIPS:Catawba/035
Date: 11/27/2018
Facility Data Permit Data
Elite Comfort Solutions Permit 10498/R00
1115 Farrington Street Issued 7/21/2016
Conover,NC 28613 Expires 6/30/2024
Lat: 35d 43.1130m Long: 81d 14.6436m Classification Small
SIC: 3086/Plastics Foam Products Permit Status Active
NAICS: 32615/Urethane and Other Foam Product(except Polystyrene) Current Permit Application(s)None
Manufacturing
Program Applicability
Contact Data
Facility Contact Authorized Contact Technical Contact SIP/112r
MACT Part 63: Subpart 60, Subpart ZZZZ
Jeff Matheney Daniel Williams Jeff Matheney
Environmental,Health& Plant Manager Environmental,Health&
Safety Manager [phone] Safety Manager
[phone] [phone]
Compliance Data
Comments:
Inspection Date 11/27/2018
Inspector's Name Sandra Sherer
Inspecto Signature: Operating Status Operating
` Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: / p 7 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
No emissions inventory on record.The emissions inventory is due 04/01/2024.
*Highest HAP Emitted inpounds)
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

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Type X Full Compliance _Partial Compliance _Complaint Other:
Action: Evaluation Evaluation/Reinspection Investigation
Data Tracking: Date submitted for initial review 11/28/2018 _ IBEAM WARNING/OB,NOD,NOV,NRE
X IBEAM Document
X IBEAM Inspection,list date inspected 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 l l/l/2020
Directions: Travel West on I-40. Take exit 130 and turn right onto Old US 70.Take a left approx. 1.4
onto Workman Street. In 0.2 miles take a left onto Farrington Street. The facility is at the end of the road.
Safety Equipment. Safety shoes, glasses and hearing protection are required at this facility.
Safety Issues: None noted.
LayLong: A review of the facility's coordinates indicate that the coordinates have not been entered into
"Maps of DAQ Regulated Facilities",however the coordinates in IBEAM appear correct.
Email Contacts: Email contacts were verified during the time of inspection.
1. The purpose of this site visit was to conduct a routine air quality inspection. This facility
manufactures poured polyurethane foam that is used in bedding, mattresses, and furniture. The
foam pouring part of the facility currently works two 12-hour shift six days per week. The looper
part of the facility works two eight hour shifts six days per week. The facility currently employs
around 190 people. Mr. Jeff Matheney,Environmental Health and Safety Manager, accompanied
me during this inspection.
2. Facility Contact Information:
During the inspection,I verified the facility contact information in IBEAM.
3. Compliance history:
This facility used to be a part of Hickory Springs Manufacturing and split away to become a
different company. While it was operating under the previous company name and the current
company name,no problems had been noted in the last five years by DAQ. The current compliance
status is discussed in the following sections.
4. Observations of permitted air emission sources and control devices:
Emission Emission Source Control Control System
Source ID Description System ID Description
ES-1 (NESHAP) foam pouring and curing N/A N/A
process

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Emission Emission Source Control Control System
Source ID Description System ID Description
.�ES-2(NESHAP) foam gluing operation N/A N/A
ES-3 (NESHAP) looper machine gluing N/A N/A
operation
ES-TANKS (NESHAP) tank farm for materials
used in the foam pouring N/A N/A
process
Observed. The Varimax foam pouring process (ES-1)was in operation during the inspection.
The foam is made by combining a set amount of chemicals,which react and quickly expand to
form into a"bun"that is run down a conveyer belt as it-forms. The system has computer
programmed A and B modes so that the type of foam being produced can change instantly. The
process uses around 200 to 440 pounds of chemicals per minute. The conveyer belt is covered on
both sides and the bottom by plastic, which is recycled. The bottom also has paper under the
plastic, which is later used as wrapping for products in other plants. The top is either open which
creates a rounded bread looking top or metal is used to square off the bun so that it forms a
straight top.The buns are about 4' by 7' and are processed at a rate of about 15-20 feet per
minute. The facility uses either carbon dioxide or acetone as a blowing agent, and acetone was the
blowing agent being used during the inspection. As the bun goes down the conveyer belt, it is
chopped into specified sizes, usually 55' for cure area No. 1 and 200' for cure area No. 2. Once
the bun is chopped,the end is labeled with a water-based spray,paint(either from a can or spray
gun) and sprayed with an adhesive. As such,this process is subject to the foam NESHAP
Subpart 000000.
The buns are very hot(about 350 degrees F) due to the exothermic reaction and are cooled using
a vacuum. Buns staying in cure area No. 1 are machine lifted where they must sit for at least
eighteen hours to cure. The buns are shipped in large tractor trailer trucks. The facility cuts the
buns into 110" pieces and compacts them, and then secures each one in place on the truck.
Around 40 to 50 pieces can fit into one tractor trailer truck since the foam is compressed by about
70 to 80%. Once the foam is compressed for shipping, however, it must arrive at its destination
and be uncompressed within three days or it will permanently remain compressed and no longer
bounce back into its original shape.
The same conveyer belt that the foam forms on can continue to cure area No. 2. This is in another
building and the buns go over a skyway into the other building. The looper machine(ES-3)
adhesive application takes 200' buns and puts them in a loop on a rollercoaster looking machine.
The ends are glued together to create one continuous loop, which is cut to make thin rolls of
foam. The rolls are then put into a Birch roller that compresses the foam for shipping. The looper
machine was not in operation during the inspection.
The foam gluing operation (ES-2)was in operation during the inspection. This machine glues
pieces of foam together to make mostly mattresses.
The tank farm(ES-Tanks) consists of approximately 60 tanks that are over 1000 gallons which
contain various POLYOS,TDI,DEOA, and reactants used in the foam manufacturing process.

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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-GENT - diesel-fired emergency generator
(168 hp) subject to NESHAP, Subpart 2Q .0102 (h)(5) Yes Yes
ZZZZ
Observed. Hour meter read 372.7 at the,time of inspection. This generator backs up the looper
system.
I-GEN2 - diesel-fired emergency generator F2Q .01102 (h)(5) Yes Yes
(54 hp) subject to NESHAP, Subpart ZZZZ
Observed. Hour meter read 493.3 at the time of inspection. This generator backs up the foam pouring
process.
I-GEN3 -diesel-fired emergency generator
(300 hp) subject to NESHAP, Subpart F2Q .0102 (h)(5) Yes Yes
ZZZZ
Observed. Hour meter read 672.6 at the time of inspection. This generator powers the fire pump.
I-WH1 -natural gas-fired water heater(1.33 F(hQT)(l)'((B)
02 Yes Yes
million Btu per hour maximum heat input)
Observed. Was not operating at the time of inspection.
I-WH2 -natural gas-fired water heater(1.44 12Q .0102 Yes Yes
million Btu per hour maximum heat input) (h)(1)(B)
Observed. Was operating at time of inspection with no visible emissions.
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. requires the facility to submit the permit renewal application.including an
emission inventory at least 90 days prior to the expiration of the air permit.
Observed. A new air permit was issued on July 21, 2016 due to expire on June 30, 2024.
Compliance is indicated.
b. Condition A.3 15A NCAC 2D .0521 "Control of Visible Emissions"shall not be more than
20 percent opacity when averaged over a six-minute period,except that six-minute periods
averaging not more than 87 percent opacity may occur not more than once in any hour nor
more than four times in any 24-hour period.
Observed. No visible emissions were noted at the time of inspection. Compliance with
this stipulation indicated.

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C. Condition A.4. 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 shall notify the Director
or his designee of any such an occurrence by 9:00 a.m.EST of the Division's next business
day of becoming aware of the occurrence.
Observed. No excess emissions have been reported by the facility. Compliance with this
stipulation is indicated.
d. Condition A.5. 15A NCAC 2D .0540, "Fugitive Dust Control". The facility shall not cause
or allow fugitive dust emissions to cause or contribute to substantive complaints or excess
visible emissions beyond the Facility boundary.
Observed. The facility has not had any fugitive dust complaints and there were no fugitive
dust emissions observed during the time of inspection. Compliance with this stipulation is
indicated.
e. Condition A.6. 15A NCAC 2D .0958(c),"Work Practices for Sources of Volatile Organic
Compounds", the Permittee shall adhere to the required work practices for storage and
clean-up of VOC-containing material.
Observed. This facility is in an attainment county for ozone and is not subject to this
stipulation. The yellowsheet has been updated to remove this stipulation during the next
permit review.
f. Condition A.7. For the Flexible polyurethane foam fabrication operations, foam gluing
operation(ID No.ES-2)and looper machine gluing operation(ID No. ES-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".
1. Standards and Compliance-Pursuant to 40 CFR 63.11416 the following standards shall
apply:
i. The Permittee shall not use any adhesive containing methylene chloride in a
flexible polyurethane foam fabrication process.
2. Recordkeeping Requirements -Pursuant to 40 CFR 63.11417 the following
recordkeeping requirements shall apply:
i. For foam fabrication operations with loop slitters,the Permittee shall retain on
site a statement signed and dated by a responsible official stating that the facility
does not use any adhesive containing methylene chloride in a flexible
polyurethane foam fabrication process.
ii. The Permittee shall demonstrate compliance with the requirements of paragraph
1.i. of this condition using adhesive usage records,Material Safety Data Sheets
or engineering calculations.
Observed. The Notification of Compliance statement was received in this office on
December 3, 2007, when this facility was still part of Hickory Springs Manufacturing.

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MSDS for each adhesive were made available to me during the time of inspection. The
facility does not use methylene chloride and has satisfied section 2.i by having a signed
and dated statement stating that the facility does not use any adhesives containing
methylene chloride. Compliance with this stipulation is indicated.
g. Condition A.8. For the Slabstock flexible polyurethane foam production operations,foam
pouring and curing process (ID No. ES-1) and tank farm for materials used in the foam
pouring process (ID No. ES-TANKS), 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".
1. Emission Standard-Pursuant to 40 CFR 63.11416,the owner or operator shall not
use any materials containing methylene chloride for any purpose in any slabstock
flexible foam production process.
2. Recordkeeping Requirements-Pursuant to 40 CFR 63.11417 and in order to
demonstrate compliance with the emission standard,the owner or operator shall
maintain records of the name and material safety data sheets for each adhesive used.
3. Reporting Requirements-Pursuant to 40 CFR 63.11417,the Permittee shall submit a
notification of compliance status report no later than 180 days after the compliance
date of July 16, 2008.
Observed. The Notification of Compliance statement was received in this office on
December 3, 2007,when this facility was still part of Hickory Springs
Manufacturing,Facility ID.No. 1800107. MSDS for each adhesive were made
available to me during the time of inspection. The facility does not use methylene
chloride. Compliance with this stipulation is indicated.
h. Condition A.9. 15A NCAC 2D .1806 "Control and Prohibition of Odorous Emissions."
Control odors properly.
Observed. No odors were detected outside the facility and MRO has not recorded odor
complaints concerning the facility. Compliance is indicated.
i. Condition A.10. 40 CFR 63-NESHAP,Subpart ZZZZ,Reciprocating Internal Combustion
Engines which are listed on the"Insignificant/Exempt Activities" list on this permit.
In accordance with 40 CFR 63.6603(a),the engines must comply with the requirements in
Table 2d since they are existing stationary RICE located at an area source of HAP
emissions.
Table 2d:
You must meet the following During periods of startup
For each. .. requirement,except during you must...
periods of startup.. .
Emergency stationary a. Change oil and filter every Minimize the engine's time spent
CI RICE and black start 500 hours of operation or at idle and minimize the engine's
stationary Cl RICE.' annually,whichever comes startup time at startup to a period
first; needed for appropriate and safe
loading of the engine,not to

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b. Inspect air cleaner every 1,000 exceed 30 minutes, after which
hours of operation or annually, time the non-startup emission
whichever comes first; and limitations apply.3
c. Inspect all hoses and belts
every 500 hours of operation
or annually,whichever comes
first, and replace as necessary.
In accordance with 40 CFR 63.6625(f), the facility is required to install a non-resettable
hour meter on the emergency generator.
In accordance with 40 CFR 63.6640(b),the facility must report each time it does not meet
the requirements listed in Table 2d. Reports must be made according to the requirements
of 63.6650.
In accordance with 40 CFR 63.6655,the facility must keep the following records:
(1) Copies of each report submitted and backup documentation for each
(2) Records of the occurrence and duration of each malfunction
(3) Records of each maintenance action performed on the subject generator
(4) Records of actions taken during periods of malfunction to minimize emissions
including corrective actions to restore malfunctioning process and air pollution
control and monitoring equipment to its normal or usual manner of operation.
(5) Records of the number of hours the generator was used for emergency operation
based on a non-resettable hour meter installed on each generator.
Observed. The facility is conducting quarterly tune-ups on the emergency generators.
I reviewed the most recent tune-ups performed on August 3, 2018. The tune-ups included
oil and filter change, and inspection of air cleaner, hoses and belts. I-GEN1, IGEN2, and
IGEN3 hour meters read 372.7, 493.3 and 672.6, respectively. Since the last inspection
conducted on May 2, 2017, I-GEN1, I-GEN2 and 1-GEN3 ran 35.4, 48.1 and 23.0 hours,
respectively. All conditions for this stipulation appear to be met.
8. NSPS/NESHAP Review
This facility is subject to NESHAP Subpart 000000 "National Emission Standards for
Hazardous Air Pollutants for Flexible Polyurethane Foam Production and Fabrication Area
Sources" and is also subject to NESHAP Subpart ZZZZ "Reciprocating Internal Combustion
Engines".
There are no boilers on site,therefore they are not subject to NESHAP Subpart 6J,and there are no
gasoline storage units on site, therefore they are not subject to NESHAP Subpart 6C.
9. Summary of changes needed to the current permit:
This facility is no longer subject to Condition A.6. 15A NCAC 2D .0958(c), "Work Practices for
Sources of Volatile Organic Compounds" because it resides in an ozone attainment county. The
yellowsheet has been updated to remove this stipulation during the next permit review.

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10. Compliance assistance offered duringthe le inspection:
None.
11. Section 112(r) applicability:
This facility is subject to the requirements of the Chemical Accident Release Prevention Program,
Section 112(r) of the Clean Air Act. This facility is under the requirements of program level one
for TDI. The last 112(r) inspection was conducted on September 7, 2017 when Mr. Chris Bagley
was the facility contact. At the time of inspection, Elite Comfort Solutions appeared to have a
complete and up-to-date RMP, demonstrating compliance with the 112(r)rule.
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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