AQ_F_1800011_20190320_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: 03/20/2019
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: 81d 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 Mark Jordan Theodore Lewis MACT Part 63: Subpart 6J, Subpart 60
Assistant Maintenance Sr VP of Upholstery Assistant Maintenance NSPS: Subpart Dc
Supervisor [phone] Supervisor
[phone] [phone]
Compliance Data
Comments.
Inspection Date 03/20/2019
Inspector's Name Sandra Sherer
Inspector's Signat Operating Status Operating
/ Compliance Code Compliance-inspection
lLit �(�.(Nt� � Action Code FCE
Date of Signature: J �' On-Site Inspection Result Compliance
Total Actual emissions in TONSIYEAR:
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 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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March 20, 2019
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Type Action: X Full Compliance —Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review: 3/26/2019 _IBEAM WARNING/OB,NOD,NOV,NRE
Tracking: X IBEAM Document
X IBEAM Inspection, list date inspected X IBEAM LAT/L.ONG,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:3/01/2020
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 20th 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: The coordinates were checked last year and were accurate. However,the site is
currently down. The coordinates in IBEAM are accurate.
Email Addresses: The email addresses for each contact 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 4th of
July holiday and for 2 days during Christmas. 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.

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4. Observations of permitted air emission sources and control devices:
Emission Emission Source Control . Control System
Source ID Description System ID Description
Furniture Finishing Operation(ID No.F-1)
ES-SB-5,ES-SB-6, five(5) dry filter-type
IES-SB-7,ES-SB-8,ES- ;paint spray booths N/A N/A
SB-9
IObserved. The booths were in operational during the inspection with no visible or odorous emissions.
Mr. Lewis stated that the filters are changed out on a weekly basis.
ES-SB-1,ES-SB-2, ]four(4)baffle filter-type.' N/A N/A
ES-SB-3,ES-SB-4 paint spray booths
Observed. These booths are now dry filter-type paint spray booths. The booths were in operation at the'
time of inspection with no visible or odorous emissions. The filters on these booths are also changed
out on a weekly basis.
ES-7-1 wash-off tank N/A F N/A
;[Observed..The wash-off tank was not in use during the inspection and was covered with a lid.
ES-LD-1 ]—furniture leg dipping N/A N/A
operation
Observed. This operation is not being used by the facility at this time.
ES-G-1 (NESHAP) gluing operations N/A N/A
Observed. The gluing operation was in operation during the inspection with no odorous emissions.
,Woodworking Operations
ES-W-1 woodworking operation i CD-C-3, CD-F-1, CD-F- ;cyclone(CD-C-3, 80
#1 4, CD-F-2 inches in diameter)
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 eight routers that vents to the silo or to the truck loadout. I observed the wood hog and
eight routers operating during the inspection with no visible emissions.

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ES-W-S woodworking operation#5 ]CD C Inches
imple cyclone(156
1 in diameter)
Observed. Woodworking operation#5 has been taken out of service.
ES-W-6 - :sample production area CD-C-; simple cyclone(60
2 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 boiler(36 million Btu fb-2 multi-cyclone(18 nine-
(NESHAP) per hour maximum heat input) inch diameter tubes)
Observed. This source is in building#2 and was operating at the time of the inspection at 25%opacity.
Wood is the only fuel that is currently being used with a feed rate of'approximately 24-28 lbs/minute.
FES-B-3 (NSPS, natural gas/No. 2 fuel oil-fired boiler(38.64 N/A , N/A
NESHAP million Btu per hour maximum heat input)
Observed. This source was not operating at the time of the inspection. This boiler is used for back-up
only. Although they are permitted to burn both natural gas and No. 2 fuel oil,the facility is only
burning natural gas. They do not currently store No.2 fuel oil for the boiler and the boiler does not havei
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:
Exemption Source of Source of Title V
Source Regulation TAPS? Pollutants?
I-ES-O-1 -natural gas-fired paint cure oven ;F(h)(1)(B)
.0102
(1.5million Btu per hour maximum heat input FYes Yes
rate). _. .
Observed.The oven was in operation during the inspection. No issues were identified.
'I-ES-0-2 -natural gas-fired shrink wrap oven 2Q 0102
(3.0 million Btu per hour maximum heat input 2Q .010 Yes Yes
rate)
Observed The oven.was in operation during the inspection. No issues were identified.
I-TANK1 —diesel fuel storage tank(1,000
gallons capacity) 2Q .0102 (g)(4) f7No No
Observed. Did not observe the tank being loaded or unloaded during the inspection.
1-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) No No
y)
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) F No No
capacity)

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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 F7Yes
F-3, 54 square feet of filter area)
The silo was processing wood to provide fuel for the boiler(ES-B2)at the time of the
[Obseecrved.
nsption with no visible emissions.
6. Observations of air emission sources and control devices not listed on the current permit:
A truck load out attached to cyclone CD-C-2 (closed system)which appears to be an insignificant
source.
7. Compliance with specific permit conditions and limitations:
a. 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-13-2) and now combusts only
natural gas fuel in the boiler (ID No. ES-13-3). The wood boiler was operating during the inspection.
Compliance is demonstrated in the last permit review.
b. Condition A.4. 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 was 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.
C. 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 properly designed bagfilters and cyclones
for their woodworking operations. They also have dry filters and baffles in their spray booths. No visible
emissions were observed from any of the exhausts. Compliance is demonstrated.
d. 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.
e. 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-I
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 and painting equipment were in operation at the time of inspection with no
visible emissions. The facility properly maintains the equipment and changes filter paper weekly on the

l
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spray booths. The coal/wood fuel-fired boiler(ES-B-2)was operating on wood at the time of inspection at
25% opacity. Compliance is demonstrated.
f. 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 does not combust No. 2 fuel oil at this time. 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 fuel combusted;therefore,they are in compliance with the recordkeeping requirements.
g. 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.
h. 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.
i. 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.
j. 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.
k. 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 by

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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 their initial tune-up on March 8, 2012 and completed a combustion
analysis on October 23,2012. Since all of the required elements of the tune-up were completed on October
23, 2012, the biennial tune-up was due by November 23, 2014. The biennial tune-up was conducted on
July 9, 2014 and included the combustion analysis and biennial compliance report. The facility is not
required to submit the biennial compliance report to MRO unless there is a deviation. The energy
assessment was completed December 9, 2013. The NOCS was submitted in CEDRI on July 14, 2014.
Copies of all notifications, tune-ups, and the energy assessment are being maintained on-site. The next
biennial tune-up was required to be conducted no more than 25 months after the July 9,2014 tune-up,which
would be August 2016. The facility conducted biennial tune-ups on boiler (ES-B-2) on August 31, 2016
and August 4,2017. The next biennial tune-up on boiler(ES-B-2) is not due until September 4,2019. The
facility maintains records of usage for both boilers 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 last tune-up on boiler
(ES-B-3)was conducted on July 9, 2014 so the next tune-up is not due until August 9, 2019. The facility
maintains a compliance document at the facility for review by the inspector.
1. 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 October 3, 2018 and February 8, 2019. The most
recent internal inspections of the multi-cyclone were conducted on November 13,2017 and May 31,2018.
The annual report for calendar year 2018 was received by this office on January 22, 2019, indicating
compliance with the permit limits. Compliance is indicated.
in. 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 0.12 tons of S02 in 2018. Compliance is indicated.
n. Condition A.17. 15A NCAC 2Q .0711, 'Emission Rates Requiring a Permit". The facility must
comply with the following limits:

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Chronic Acute Acute
Pollutant Carcinogens Toxicants Systemic Irritants
(lb/yr) (lb/day) Toxicants (Ib/hr)
(lb/hr).
Ethyl acetate(141-78-6) 147.41
MEK(methyl ethyl ketone,2-butanone)(78- 155.8 93.19
93-3) . . F � ...
MIBK(methyl isobutyl ketone) (108-10-1) 107.8 31.59
Toluene(108-88-3) 197.96 1 F758.97
Xylene(mixed isomers)(1330-20-7) F 113.7 _ 68.44
Observed. The facility's production has not significantly changed since CY2015. 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 3,680 lbs. of toluene in 2018 remaining well
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-13-3)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:
Future inspections should include a representative from MRO's permitting section due to the
configuration of the control devices. The inspector should notify the MRO Permit Coordinator PRIOR to
future inspections.Refer to woodworking operations as being conducted in buildings#1 and#2 and look
at description of the controls: ES-W-5 is not being used and probably should be taken off permit.
Remove CD-F-1 from permit. Add 2°d cyclone 80 inches in diameter on building#2 in closed loop. Add
a truck loadout in building#2 to insignificant source list.
10. Compliance assistance offered duringthe he inspection:
None noted.
11. Section 112(r) pplicability:
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.
SLS:lhe
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