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HomeMy WebLinkAboutAQ_F_0900081_20150827_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Gildan Yarns,LLC Plant 71 NC Facility ID 0900081 Inspection Report County/FIPS:Bladen/017 Date: 09/10/2015 Facility Data Permit Data Gildan Yams,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/Yarn Mills,Except Wool Permit Status Active NAICS: 313 Ill /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 (910)647-1132 (704)638-5112 (704)638-5112 Compliance Data Comments: Inspection Date 08/27/2015 Inspector's Name Neil Joyner Inspector's Signature: Operating Status Operating `vV I y Compliance Code Compliance-inspection r Action Code FCE Date of Signature: -- L Q Q On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP SO2 NOX VOC CO PM10 *HAP 2013 03300 --- --- --- 0.1426 --- 2008 0.2100 --- --- --- -- 0.0900 --- *Highest HAP Emitted(in pounds) Five Year Violation History:None Date Letter Tvue Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested GACT/MACT Considerations and Compliance: The facility has a 135 brake horsepower fuel oil fired fire pump engine made in CY1989 with non- resettable hour meter that is exercised—30 minutes each week. According to their current air permit, the engine is subject to the requirements of NESHAP Subpart 4Z as an existing engine. On 12 September 2014,my office had previously emailed the facility a copy of the NESHAP Subpart 4Z requirements regarding this engine. Deviations Noted: Mr.Bedsole stated that the facility did not have documentation available regarding the required NESHAP Subpart 4Z inspection and maintenance activities for this engine. He stated that Stewarts Mobile Service was performing these activities once each year, but that he did not have any receipts or other documentation showing this. I also noted in the engine log book that the facility did not appear to be documenting the times and reasons of engine operation. On 2 September 2015,I spoke again with Mr. Bedsole by phone and requested his receipt from Stewarts Mobile Service. Since then,I have not received the receipt. Directions: From FRO take Highway 87 about 34 miles to Elizabethtown(stay on Bypass); turn right onto Hwy 701 South;travel about 10 miles into Clarkton;turn right onto Highway 211. The facility is about''/2 mile on the right. Park in the first lot and use the door by the flags. Safety Equipment: All standard DAQ FRO safety gear is required. Be aware that machinery is possibly operating during the inspection. The principal hazards to the unwary inspector are noise and pinches and scratches because of the air pressure-driven doors. Facility Description: Gildan Yarns 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 realms. 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 received 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 wash 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. The facility has a 135 brake horsepower fire pump engine made in CY1989 with non-resettable hour meter that is exercised—30 minutes each week. Number of Employees: 134 Hours of Operations: 24 hours per day; 7 days per week; closed Christmas week Thread produced in CY2014: 38,135,295 pounds Emission Sources and Operating Status: The facility has a general permit for yarn spinning that covers the following: (1)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. (2)Combustion equipment firing No.2 fuel oil/natural gas with a combined total maximum heat input not to exceed 45 million Btu per hour. -This facility does not have combustion equipment on-site, except for the 135brake horsepower no. 2 fuel oil fired fire pump engine that was not operating at the time. Insignificant/Exempt Activities e g �, �Z'IMA W- 0 ft_ �.5. Y:s� 3:i 2n:i'�"d"�Y r f �i3 E� - I-FIRE PUMP 135 HP diesel-fired fire pump(NESHAP 2Q .0102(c)(2)(B)(v)(I) FYes Yes Subpart ZZZZ) -Not operating. Inspection Summary: On 27 August 2015, I,Neil Joyner, DAQ FRO, met with Mr. Steve Bedsole,Plant Engineer,to conduct a compliance inspection. Mr.Bedsole stated that there was no new process or equipment at the facility related to air quality and none were planned. He reviewed the FACFINDER and no corrections were needed. He stated that he had received no complaints from anyone regarding air quality. He stated that no exhausts from the air filtration systems are released into the outside air but are re-entered back into the plant. Mr. Bedsole led me around the facility and explained the process. He took me to the air filtration systems located in separate areas around the outside rooms of the facility.Mr. Bedsole advised against photography because of the potentially explosive nature of the organic dust, and camera flashes that could set off the fire extinguishing system. I toured the entire site that day including walking around the outside perimeter of the building. 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 side of the building. Regulatory Review: A.3 2D .0503 "Particulates from Fuel Burning Indirect Heat Exchangers"—Particulate matter emissions from the fuel burning indirect heat exchangers shall not exceed the allowable emission rates. Appeared in Compliance-The facility has no fuel burning indirect heat exchangers on site. A.4 2D .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 by the permit writer,based on operating these sources as in the permit application. There have been no changes to these sources. 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 only combustion equipment at the site is a 135 brake horsepower no. 2 fuel oil fired fire pump engine that is exercised for—30 minutes each week. 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. 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. The cotton waste receiving dump truck was not operating at the time. A.10 NCGS 143-215.107 (a) (4) "Reporting Requirements" -The Permittee,within 30 days after the end of each calendar year, shall report in writing 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 CY2014 was received by 30 January 2015. A.11 20 .0310"Permitting of Numerous Similar Facilities"-The facility shall qualify for this permit provided the following conditions are complied with: a) The facility does not operate any emission sources other than emission sources as listed specifically in this permit. b) The facility is not subject to any other 2D or 2Q regulation not addressed in Specific Condition No. 1. c) The facility shall not process more than 490,000,000 pounds of ginned cotton per consecutive twelve month period. d) To comply with the provisions of this permit and ensure that optimum control efficiency of air filtration system is maintained,the Permittee shall establish an inspection and maintenance schedule/checklist based on manufacturer's recommendations. This inspection and maintenance schedule shall be followed throughout the yarn spinning time period. The results of these inspections and any maintenance performed on the air pollution control equipment shall be recorded in a log book. The log book shall be made available upon request. e) The facility's storage tanks(if applicable)are used solely to store fuel oils, kerosene,diesel, crude oil,used motor oil,natural gas, gasoline or liquefied petroleum gas and are exempted from permitting under 2Q .0102(c)(1)(D).. Deviations Noted- a) The facility does not operate any significant emission sources other than those listed specifically on the permit. b) The facility is not subject to any other 2D or 2Q regulation not addressed in Specific Condition No. 1, except 2D .I I I I "National Emission Standards for Hazardous Air Pollutants"- Reference the fire pump engine,"The Permittee shall comply with all applicable provisions, including the maintenance and recordkeeping requirements contained in 2D .1111, as promulgated in 40 CFR 63, Subpart ZZZ". This engine is exempted from permitting under 2Q .0102(c)(1)(D). c) The facility processed 38,135,295 pounds of ginned cotton during CY2014. d) Mr.Bedsole stated that the required air filtration system inspection schedule for this facility was that inspections be performed at least once each month,but he stated that he has nothing written down about it. Inspection and maintenance log books were available at the locations of each filtration device station. I noted that the fabric filter house no. 4 log book indicated that the last inspection was on 18 March 2015,but there were no entries for subsequent months. I also noted that the filter house no. 6 log book was missing entries for three months over the past twelve months. Mr.Bedsole stated that required monthly inspections had been done on houses no.4 and 6, but the worker had failed to document all of them. He also provided a printout of maintenance activities that had been performed on the filter houses. e) The facility has a no. 2 diesel fuel storage tank on the site for the 135 brake horsepower fire pump engine that is exempted from permitting under 2Q .0102(c)(1)(1)). A.12 20 0310(d) "A Permittee shall be subject to enforcement action for operating without a permit if the facility is determined not to qualify under the terms and conditions of the general ep rmit" Appeared in Compliance—Based on the results of this inspection,the facility appears to qualify for its current general air permit. 112r Applicability: Through observations and discussions with facility personnel,this facility does not require a written risk management plan;reference 40 CFR Part 68,Accidental Release Prevention. Non-Compliance History since CY2010: No non-compliance issues since CY2010. Recommendations and Compliance Statement: Based on review of records and visual observations, this facility appeared to be operating in compliance with their air quality standards and regulations at the time of this inspection, except for the deviations noted above. Recommend recordkeeping NOD for: Air Filtration System: (1)no documentation of the inspection and maintenance schedule/checklist was available, and(2)several of the facility's previous inspection results were not recorded in the designated log books on the site. Fire Pump I-FIRE-PUMP: (1) no records were available for the required engine maintenance and work practices, and (2)no records were available of the hours of engine operation and how many hours were spent for emergency and/or non-emergency operation. Notes to Pink Sheet:No new notes needed at this time. /caj