AQ_F_0100204_20190328_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY McComb Industries, LLLP
NC Facility ID 0100204
Inspection Report County/FIPS:Alamance/001
Date: 03/28/2019
Facility Data Permit Data
McComb Industries, LLLP Permit 04662/RI 1
1311 Industry Drive Issued 3/7/2018
Burlington,NC 27215 Expires 7/31/2022
Lat: 36d 3.5160m Long: 79d 26.3640m Class/Status Synthetic Minor
SIC: 2262/Finishing Plants, Synthetics Permit Status Active
NAICS: 313311 /Broadwoven Fabric Finishing Mills Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact
SIP
John Small Todd Whitley Danny Crouse
Maintenance Manager President R& D Manager
336 229-9139 336 229-9139 336 229-9139
Compliance Data
Comments:
Inspection Date 03/28/2019
Inspector's Name Chris Bryant
Inspector's Signature Operating Status Operating
Compliance Code Compliance- inspection
L / Action Code FCE
l l Date of Signature: / MTH On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PMIO * HAP
2013 0.9700 0.0100 2.39 1.31 2.00 0.9300 396.00
2008 66.88 0.0200 2.85 2.45 2.39 — 66.88 990.00
* Highest HAP Emitted in ounds
Five Year Violation History:None
Date Letter T e Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE: None
Date Test Results Test Methods) Sources)Tested
Permitted Sources
Emission Emission Source Control Control System
Source ID Description System ID Description
F-2.I, F-2.2 l _.
Four(4)atmospheric beam tanks N/A N/A
F-23, F-2.4 �
Natural as-fired textile finishin oven Fume eliminator
(1296 square feet of
ES-1 (9.0 million Btu per hour maximum heat input) CD-1 , filter area)
�ES-2 Hot oil-heated textile finishing oven CD-2 Fume eliminator
(1,512 square feet of filter area)
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Insignificant/Exempt Activities _ _
Source mption—ISour__ce of Source of Title
Regulation TAPS? V Pollutants?
I-ES-10 -Natural gas/No.2 fuel oil-fired hot oil heater
(7.76 million Btu per hour maximum heat input)
I-ES-30 Natural gas/No.2 fuel oil-fired boiler , 2Q .0102
(16.74 million Btu per hour maximum heat input) j (h)(1)(A) Yes Yes
I-ES-40-Natural gas/No.2 fuel oil-fired boiler
(16.8 million Btu per hour maximum heat input) j
1 ES-5 I ES-6 -Two(2)pressurized dye tanks
I-ES I1, I-ES-12, I ES-13 I ES-14, I ES-15, I-ES-16,I-ES-17- 9 2Q(g)(14��B) Yes Yes
Seven(7)pressurized dye machines
I-ES-ST-Underground No.2 fuel oil storage tank(15,000 gallon capacity) 2Q .0102(g)(4) Yes Yes
Introduction
On March 28, 2019, Mr. Chris Bryant, Environmental Specialist of the DAQ WSRO, contacted Tim Kauwell,
Maintenance Manager at McComb Industries, LLLP for an unannounced targeted compliance inspection. Since the last
inspection, Mr. Kauwell has replaced Mr. John Small as the Facility Contact/Maintenance Manager. Mr. Kauwell was
very knowledgeable of the processes and emission sources and was helpful in assisting in the inspection. The facility was
previously inspected on February 20, 2018 by Mohammad Khan, Environmental Chemist of WSRO-DAQ,and was found
to be in compliance with DAQ rules and regulations at that time. The contact information has been updated in IBEAM.
All other contact information including addresses, numbers, and titles are accurate in [BEAM. The facility nits, dyes, and
finishes fabrics such as nylon, polyester, and Lycra. These fabrics are manufactured for bed sheets, clothing, pant bands,
and shoe lining. The facility operates two shifts(7am-3pm, 3pm-12am). The 14 hours of production time was referred to
by the facility contact as"pinning"time. The facility has about 70 employees.
Safety Equipment
Safety shoes, safety glasses, and hearing protection are required equipment when inspecting this facility.
Latitude/Longitude Verifications
The latitude and longitude coordinates were verified to be accurate as documented in [BEAM.
Applicable Regulations
According to Permit Condition A.1 the facility is subject to the following regulations: Title 15A North Carolina
Administrative Code(NCAC), Subchapter 2D .0202, 2D .0503, 2D .0515,2D .0516, 2D .0521, 2D .0535, 2D .0540, 2D
.1806, 2Q .0315, and 2Q .0711. This facility is not subject to RMP requirements of the 112(r) program since it does not
use or store any of the regulated chemicals in quantities above the threshold levels in the rule. The facility is only subject
to the General Duty requirements contained in the General Duty Clause.
Discussion
The new facility contact,Tim Kauwell, met the inspector and reviewed the air quality regulations as noted in Permit
04662RI 1. Mr. Kauwell, Maintenance Manager, was familiar with the permit and had worked with the former facility
contact,John Small. The facility receives and knits fabrics including nylon, polyester, and Lycra. These fabrics are then
dyed and cured. First, Mr. Kauwell escorted the inspector into the dye house area. The seven pressurized dye machines
(I-ES-I I through I-ES 17) were observed. Five were adjacent to each other and the other two were on the left side. The
two pressurized dye tanks(I-ES-S, 1-ES-6)were also observed. These insignificant sources were not in use during the
inspection. These tanks are inspected yearly by the company to monitor the heat and pressurizing capacities as well as the
structure of the tank itself. The implementation of the dye solutions requires consistent temperatures and pressures to
accommodate the specific fabrics and colors. The polyester material must be introduced to the dye colors at>265°F for a
period of at least 30 minutes. The nylon is dyed at 215°F. Next, the four atmospheric beam "dip"tanks(F-2.1, F-2.2, F-
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2.3, F-2.4) were observed. Large spools of fabric are dunked into the tanks, brought up to 205°F,and additional
chemicals are added. This ensures that all the moisture is forced out of the material. These four tanks were not in use
during the inspection. The facility currently only uses the hot oil-heated finishing oven (ES-2) and the associated fume
eliminator(CD-2). The oven operates at a range of 325-415°F. Textile oven,ES-2, is heated via the natural gas/No.2 oil
fired heater/boiler. This finishing oven and control device were in use for a portion of the inspection. Mr. Bryant
observed the visible emissions from the oil heated oven and eliminator immediately upon arrival to the facility. At that
time, emissions were between 10-15%opacity, but wind and gray skies hampered the visible evaluation. There didn't
appear to be any violations of the 20% opacity limit during the 20 minutes the inspector observed the stack. The second
finishing line (consisting of the natural gas-fired finishing oven, ES-1, and fume eliminator, CD-1), were not being used
and have not been operational for a few years. Mr. Kauwell thought that the units were not going to be put back into
service as they needed a substantial number of repairs to be brought back on-line. The facility may want to consider
removing this emission source from the source list when the permit goes up for renewal if applicable.
The facility has two in significant/exempt dual fuel (natural gas/No.2 fuel oil) boilers, I-ES-30 and I-ES-40 and one hot oil
heater(I-ES-10)on-site. The dual fuel hot oil heater was operating at 490°F and 48 psi. Units 1-ES-30 and I-ES-40
alternate week-to-week and I-ES-40 was on and reading 3757 and 115 psi. The boilers maintenance information is kept
by Mr. Kauwell. Also, tune-ups continue to be performed by Matt Marshall and Company, boiler parts and service, out of
Greensboro,NC. Mr. Kauwell confirmed that the facility has not burned any No. 2 fuel oil over the past 4-5 years and did
not plan on using any in the future. The facility has an exempt/insignificant underground storage No.2 fuel oil tank that
has a 15,000-gallon capacity, although Mr. Kauwell thought the tank was empty at the time.
Permit Conditions/Applicable Regulations
Condition A.2 contains the 15A NCAC 2D .0202 permit renewal and emissions inventory requirements. The facility was
issued the most recent permit on March 7, 2018 after submitting a name change from"Alexander Fabrics, LLLP"to
"McComb industries, LLLP." The permit expires on July 31, 2022,and the facility must submit a renewal request and air
pollution emission inventory report for the 2021 calendar at least 90 days prior to the expiration of this permit. This
condition was discussed with Mr. Kauwell. Compliance is expected.
Condition A.3 contains the 15A NCAC 2D. 0503 "Particulates from Fuel Burning Indirect Heat Exchangers"
requirement. This condition applies to the natural gas-fired textile finishing oven (ES-1), the natural gas/No. 2 fuel oil-
fired hot oil heater(I-ES-10), and the two-natural gasMo. 2 fuel oil-fired boilers(I-ES-30 and I-ES-40). The following
table is borrowed permit review R10(Taylor Hartsfield, August 8, 2014):
- --- - _ _- _- _._
i Emissions r ^Construction
Indmdual Heat Input Maximum Heat Input Allowable Emission Rate
Source ID Date Rate [MMBtu/hr] Rate(Q) [MMBtu/hr] (E) [Ibs/million Btu]
ES-1 2009 9.0 50.3 039
--— I -._- _ --
1-ES-10 1985 7.76 7.76 0.60
1-ES-30 1988 -16.74 41.3 0.42 ......._ .m ._
-ES-40 1988 16.8 41.3 0.42
The emissions rates were calculated and deemed acceptable for combustion of both natural gas(0.0075 Ibs/MMBtu)and
No. 2 Fuel Oil (0.024 Ibs/MMBtu). Compliance is expected.
Condition A.3 contains the 15A NCAC 2D .0515 particulate control requirement. This condition sets the maximum
allowable particulate emissions for the natural gas-fired oven (ES-1) and the hot oil-heated finishing oven (ES-2).
E=4.10 * (P)°67 for P<=30 tons/hr,or
E=55 * (P)e"-40 for P>30 tons/hr
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The following table, which is based on CY2013 emissions inventory, is borrowed permit review R10 (Taylor I lartsfield,
August 8, 2014):
Emissions Source Process Weight Rate Allowable Emissions Actual Emissions Rate*
(P)[tons/hr] ! Rate(E) jibs PM/hr] fibs PM/hr]
Natural gas-fired textile finishing oven(ES-1) 0.366 I 2.09 0.79
Hot oil-heated textile finishing oven(ES-2) ) 0.366 2.09 Did not operate
*Calculated by taking actual emissions in tons per year times 2000 pounds per ton divided by the number of hours the source operated in CY2013 as
reported in the emissions inventory.
Actual emissions are less than the allowable emissions and compliance is demonstrated.
Condition A.5 contains the requirements for 15A NCAC 2D. 0516, "Sulfur Dioxide Emissions from Combustion
Sources."The rule, which applies to the natural gas-fired textile finishing oven (ES-1), the natural gas/No. 2 fuel oil-fired
hot oil heater(1-ES-10), and the two-natural gas/No. 2 fuel oil-fired boilers (I-ES-30 and 1-ES-40), states that the facility
shall not exceed 2.3 Ib/MMBtu of sulfur dioxide emissions. The emissions were calculated to be 0.00059 Ib/MMBtu from
the combustion of natural gas and 0.507 Ib/MMBtu from the combustion of No. 2 fuel oil. Compliance is expected.
Condition A.6 contains the 15A NCAC 2D .0521 visible emissions control requirement. This facility is limited to 20%
opacity visible emissions, for sources manufactured after July 1, 1971,when averaged over a six-minute period. The
opacity observations on the finishing oven,ES-2,and fume eliminator were between 10-15%. Compliance is expected.
Condition A.7 contains the 15A NCAC 2D .0535 notification requirement for excess emissions during a malfunction or
breakdown that lasts for more than 4 hours. No incidents or malfunctions were reported. There are no issues registered in
IBEAM for this facility. Mr. Kauwell was not aware of any malfunctions occurring. Compliance with the condition is
expected.
Condition A.8 contains the 15A NCAC 2D .0540 fugitive dust control requirement. No fugitive dust was observed
traveling beyond the property boundaries during this inspection. According to the DAQ (BEAM database, no complaints
have been received regarding fugitive dust emissions at this facility. Compliance with this condition is expected.
Condition A.9 contains the 15A NCAC 2D .1806 control of odorous emissions requirement. No objectionable odors
around the facility boundary were noted during the inspection. There have been no complaints regarding odors at the
facility. Compliance with the condition is expected.
Condition A.10 contains the 15A NCAC 2Q .0315 "Synthetic Minor Facilities" limitation to avoid the applicability of
I SA NCAC 2Q .0501.The facility requested this limitation to obtain a synthetic minor classification and avoid being
classified as a Title V facility.The facility must control particulates from the natural-gas fired (ES-1)and hot oil heated
textile finishing oven(ES-2) with the fume eliminators(CD-1, CD-2). The facility should conduct routine maintenance,
inspections, repair as needed,and follow appropriate manufacturer's guidelines. At a minimum,the facility must perform,
annually, an internal inspection on each device and record the results in a logbook. This annual requirement should
include inspections of spray nozzles, packing material, chemical feed system (if applicable), and the cleaning/calibration
of all associated instrumentation. McComb Industries conducted bi-annual inspections and maintenance on the affected
sources. The most recent internal inspection was performed on December 23, 2018. The facility performs these bi-annual
inspections during the July 4 and Christmas holidays. In addition, the facility performs maintenance as needed and
records the events in an electronic spreadsheet. Compliance is expected
Condition A.11 contains the 15A NCAC 2Q. 0711 requirements pursuant to"Emissions Rates Requiring a Permit."The
facility may not exceed any of the Toxic Permit Emission Rates(TPER)as listed in the 2Q .0711 regulations. Prior to
exceeding any TPER,the facility must modify their air quality permit. The triggered toxic air pollutants include, Acetic
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acid, Ammonia, Benzene,Chlorine, Formaldehyde, Perchloroethylene(tetrachloroethylene), and toluene. The following
table is borrowed from permit review RI (Taylor Hartsfield, August 8, 2014)and reflects the emissions and the TPER
limits associated with each toxin.
Toxic Air Pollutant(CAS#) TPER 2013 Actual Emissions*
Acetic acid(64-19-7) 0.96 Ib/hr 0.19 Ib/hr
Ammonia(as NH3)(7664-41-7) 0.68 lb/hi- 0,038 lb/hr
Benzene(71-43-2) - 8.1 Ib/yr 0.1 Ib/yr
Chlorine(7782-50-5) 0.79 lb/day;0.23 Ib/hr (-- _ Not reported
Formaldehyde(50-0010) � 0.04 Ib/hr � 0.0016 Ib/hr
.-_--- - -- - -- - - --- - ---
Perchloroethylene-(tetrachloroethylene-- )(127-18-4) 13,000 Ib/yr �� - 27.5 lb/yr
Toluene(108-88-3) 98 lb/day; 14.41b_r 1.63 * 10-3 lb/day;3.39* 10-s lb/hr
�*Calculated using reported emissions in units of pounds per year and converting units based on 2013 actual operation scenario of 20 hours per day,
5 days per week,and 48 weeks per year.
-__ ........_..---- --_..-_------
.-._..-.-...
Compliance is expected
NSPS/NESHAP
The regulation 2D .l 1 1 1 and NESHAP 40 CFR 63 Subpart JJJJJJ (6J) for"Industrial, Commercial, and Institutional
Boilers at Area Sources" for the exempt two natural-gas/No. 2 fuel oil-fired boilers(I-ES-30 and I-ES-40) applies.
However, the facility is avoiding the applicability by taking the special exemption for liquid fuel backup. The facility
must only burn natural gas except for periods of gas curtailment, gas supply interruptions, startups, or for periodic testing
on liquid fuel. The facility has not used liquid fuels in the boilers and has no intention or expectation of switching from
natural gas.
Facility Wide Emissions
Actual emissions, based on 2013 emission inventory information are borrowed from permit review R10(Taylor
Hartsfield,August 8, 2014)
Pollutant Actual Emissions [tons/year] without controls o teo��n al Emissionsv���h controls and limits
(CY2013
PM _ 0.97 _. 297.13 7.44
P M 1 o 0.93 294.09 4.40
PMzs 0.04 0.39 0.39
SOz 0.01 91.76 91.76
NO, 2.39 29.70 29.70
... .CO 2.00 18.15 _._. ( 18.15_.._-_,.____.
VOC__.._-- 1.31-_--__-.----'----__ 4.72 4.72
...... - -- --.-..-
HAPrmai j" 0.32 1.71 L71
HAPH;Rhut(Glycol ethers) 0.20 0.72 ( 0.72
Permit issues
The facility may consider removing the natural gas-fired finishing oven (ES-1) and associated fume eliminator from the
permit during the next renewal if the equipment would not be used again.
Compliance History
This facility has not been issued a NOD, NOV, or NOV/RE in the past 5 years.
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Conclusion
Based on visual observations and review of records, McComb Industries, LLLP appears to be in compliance with all
applicable Air Quality standards and regulations at the time of this inspection.
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