AQ_F_0900081_20160901_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Gildan Yams,LLC Plant 71
NC Facility ID 0900081
Inspection Report County/F1PS:Bladen/017
Date: 09/21/2016
Facility Data Permit Data
Gildan Yarns,LLC Plant 71 Permit 09529/G04
820 West Highway 211 Issued 11/21/2014
Clarkton,NC 28433 Expires 10/31/2022
Lat: 34d 29.6060m Long: 78d 401260m Classification Small
SIC: 2281 /Yam Mills,Except Wool Permit Status Active
NAICS: 313111 /Yarn Spinning Mills Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Ron Daniel Randall Ferguson Randall Ferguson
Plant Manager Director of Engineering Director of Engineering
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 09/01/2016
p �/ Inspector's Name Pam Vivian
Inspector's Signature: `/ X,w U.J,` etv Operating Status Operating
Compliance Code Compliance-inspection
J Action Code FCE
Date of Signature: �1/ Zl f��� On-Site Inspection Result Compliance
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Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2013 0.3300 --- --- --- --- 0.1426 ---
2008 0.2100 0.0900 ---
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
1)Directions:
From FRO take Highway 87 south towards Elizabethtown staying on the bypass; turn right onto
Hwy 701 south towards Clarkton;turn right onto Highway 211; facility is on the right; park in the
first lot and use the door by the flags.

2) Safety Equipment:
All standard FRO DAQ safety gear. Be aware of various machinery operating; be aware of noise,
pinches,and scratches because of air pressure-driven doors.
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3)Process/Facility Description:
This is a cotton and cotton-blend spinning mill. It is necessary for the plant process to maintain the
air temperature and relative humidity in the plant,respectively at 75 to 78 degrees F and 63 percent.
The facility has two sections of cotton thread machines: Side A with 18 machines and Side B with 28
machines.
Bales of ginned cotton are processed using several cleaner blender-mats to remove the cotton waste
from the usable fibers. The fibers go through multi-mixer CVT guard machines and are drawn to
frames machines where the fibers are spun into continuous loose strands that are barely held together
in thick appearing rope type strands. These spun fiber strands are accumulated through a special
computerized process, into large barrels that are fed to the open-end spinner machines where it is
spun into 8-count thread reams. The facility produces a 50/50 polyester/cotton blend thread and a
100%cotton thread. The cotton waste is again recycled through the process, and the final wasted
matter is collected outback by a dump truck that transports it off site for agricultural use.
Air Filtration Systems:
There are 4 fabric filter house units and 3 air wash scrubber units with associated fabric filter lined
rotating drums,which all remove particle matter. The fabric filters are used to remove larger particle
matter before the air is drawn through a series of water wet scrubber type spray nozzles. This wash
removes smaller particle matter and aids in the needed control of the facility temperature and
humidity levels. The large amount of water used for the scrubber system is filtered through a special
screen and reused for the wet scrubber control device. Winter months require less water use, whereas
the summer months require a greater usage of water. From the air wash units,the air is put through a
fabric filter lined rotating drum and then exhausted back into the plant. Exhausts from these control
devices are not released into the atmosphere but re-enter back into the plant.
Fire pump engine:
The facility has a 135 brake horsepower engine manufactured in CY1989 with non-resettable hour
meter that is exercised—30 minutes each week and only used for facility emergency reasons.
4)Equipment List:
Permitted Sources:
The facility has a general permit for yarn spinning that covers the following:
- Emission sources associated with the air filtration system(s)utilized in the yarn spinning
process(Standard Industrial Classification Code(SIC)2281,2282, and 2284);
-Operating at—4300 pounds of thread per hour;—0% opacity.
Insienificant/Exempt Activities:
MM
I-FIRE PUMP _. t
135 HP diesel-fired fire pump(NESIIAP 2Q.0102(c)(2)(13)(v)(I) Yes Yes
Subpar[ZZZZ)
-Not operating

5)Inspection Summary:
On 1 September 2016, I, Pam Vivian with FRO DAQ met with Mr. Ron Daniel, Plant Manager,to
conduct a compliance inspection. Mr. Daniel stated that no new process or equipment has been
added to the facility since the last inspection. He stated the facility had not received any air
complaints and there have not been any excessive emissions. He reviewed the FACFINDER and
provided the current air permit. He said that individual UM logs are kept at each of the air filtration
units and fire pump engine building. He said there had been no emergencies requiring the fire pump,
only test runs and maintenance. He provided an invoice dated 22 September 2015 from Stewart's
Mobile Service who annually perform UM on this engine. He said they would return later this month
to perform another annual UM. He said facility employees perform monthly checks and general
maintenance as needed and record this in the UM log.
I asked about the emails that were sent to Mr. Ferguson concerning the new permit rules update on 17
June and 29 August 2016. I provided him a copy of the email's attachments concerning them and
said to call Mr. Greg Reeves with FRO DAQ for any concerns or questions. He said he has heard
conversations between Mr. Ferguson and other officials but no decision has been made at this time. I
told him the annual permit fee was due and if it had not been paid he should bring this matter up to
Mr.Ferguson. He said he would discuss this with Mr. Ferguson.
Mr. Daniel guided me during this inspection. We went to the air filtration systems located in separate
areas around the outside rooms of the facility. Mr. Daniel advised against photography because of the
potentially explosive nature of the organic dust, stating the camera flash could set off the fire
extinguishing system. Mr. Daniel guided me throughout the entire facility including outside of the
perimeter of the property. The air filtrations systems did not appear to be exhausting to the outside air
and I noticed negative air pressure at the filtration system louvers located on the sides of the building.
Mr.Daniel stated that no exhausts from the air filtration systems are released into the outside air but
are re-entered back into the plant on go through the system again.
Mr. Daniel took me to the brick building which houses the 135 brake horsepower fire pump engine
for only facility emergency needs. The engine hour meter read 181.5 on 9/1/2016 and 156.7 hr on
9/21/2015. He told me the facility employees about 140 workers and continues to operate 24 hr/day,
Monday through Sunday,but is closed the week of Christmas.
Throughputs:
Year Pounds of bales cotton
2016 (as of 08/31/2016) —36,000,000
2015 40,435,096
2014 38,135,295
6)Permit Stipulations:
A.2 20 .0203—"Permit Renewal and Emission Inventory Requirement"—At least 90 days prior
to the expiration date of this permit,the Permittee shall submit the permit renewal and emission
inventory.
Appeared in Compliance—The recent permit renewal was due by 30 November 2014 and was
received on 24 October 2014. Next permit renewal and EI are due in July 2022.
A.3 2D .0503—"Particulates from Fuel Burning Heat from Fuel Burning Indirect Heat
Exchangers"—Particulate matter emissions from the fuel burning indirect heat exchangers shall not
exceed the allowable emission rates.
j Appeared in Compliance-The facility has no fuel burning indirect heat exchangers on site.
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A.4 21) .0515 "Particulates from Miscellaneous Industrial Processes"—Particulate matter
emissions from the emission sources shall not exceed allowable emission rates.
Appeared in Compliance- Compliance was determined during the most recent permit review based
on operating the source as described in the permit conditions. No changes have been made to
operations since that determination.
A.5 2D .0516 "Sulfur Dioxide Emissions from Combustion Sources"—Sulfur dioxide emissions
from the emission sources shall not exceed 2.3 pounds per million Btu heat input.
Appeared in Compliance-The fire pump engine combusts ULSD. The AP-42 emission factor for j
this fuel is 0.002 lbs/mmBtu.
A.6 2D .0521 "Control of Visible Emissions"—Visible emissions from the emission sources,
manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged over a six-
minute period.
Appeared in Compliance—No visible emissions were observed at the time of this inspection.
A.7 2D .0521 "Control of Visible Emissions"—Visible emissions from the emission sources,
manufactured prior to July 1, 1971, shall not be more than 40 percent opacity when averaged over a
six-minute period.
Appeared in Compliance—Facility does not have equipment manufactured prior to 1 July 1971.
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A.8 2D .0535 Notification Requirement,-Facility is required to notify the DAQ of excess
emissions that last for more than four hours resulting from malfunction,breakdown, or abnormal
conditions.
Appeared in Compliance—Mr.Daniel stated there have been no occurrences of excessive emissions
since the last inspection.
A.9 2D.0540 "Particulates from Fugitive Dust Emission Sources," -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.
Appeared in Compliance—No fugitive dust emissions were observed. Facility grounds are paved
and landscaped.
A.10 NCGS 143-215.107 (a) (4) "Reporting Requirements" -Within 30 days after the end of each
calendar year, a report should be sent to this office stating the pounds of cotton processed each month
for the previous 12-month period.
Appeared in Compliance-The annual report for the pounds of cotton processed for CY2015 was
received by 29 January 2016.
A.11 20 .0310 "Permitting of Numerous Similar Facilities"-The facility shall qualify for this
permit provided the following conditions are met: Operate only permitted emission sources;Facility
not subject to any other 2D or 2Q rules as specified in Stipulation 1; Shall not process more than
490,000,000 lbs of ginned cotton per year; Maintain optimal control efficiency of air filtration
system;Perform I/M per manufacturer's recommendations throughout the yarn spinning time period,
record these UM, and other maintenance performed in a log book which is available upon request;
Facility storage tanks are solely used to store various fuel oils,NG,or LPG and, are exempt from
permitting per 2Q .0 1 02(c)(1)(D).
Appeared in Compliance—
Facility does not operate any emission sources other than listed on the permit;

Facility is not subject to any 2D or 2Q regulations as specified in Stipulation 1 except 2D
.I I I I `NESHAP' for the fire pump engine which is exempt from permitting under 2Q
.0 1 02(c)(1)(D).
The facility processed 40,435,096 pounds of ginned cotton during CY2015.
Air filtration systems had a log at each unit indicating I/M. Mr. Daniel said all unit logs are
compiled into one electronic log. He provided me a copy of this log which indicated I/M
performed to include component changed dates(see attached log).
Facility has no fuel oil,NG, or LPG tanks stored on site; fuel directly added to the fire pump.
A.12 20 .0310(d) "A Permittee shall be subject to enforcement action for operatine without a
permit if the facility is determined not to qualify under the terms and conditions of the eeneral
permit.
Appeared in Compliance—Based on the results of this inspection, the facility appears to qualify for
its current general air permit.
7) 112r Status:
The facility does not use or store any chemicals on the property that would make them subject to a
written Risk Management Plan as required under 40 CFR Part 68.
8)Non-Compliance History since CY2010:
On 11 September 2015, an NOD was submitted due to record-keeping of Air Filtration System and
Fire Pump, I-FIRE PUMP. Response was received on 28 September 2015.
9) Comments/Compliance Statement:
This facility appeared to be well operated and maintained as of this inspection. Past record-keeping
deficiencies appear to have been corrected. Gildan Yarns,LLC Plant 71 appeared to be operating in
compliance during this inspection.
Pink Sheet:
None.
/pcv
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