AQ_F_1200107_20220216_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Valdese Weavers, LLC -Lovelady Road Plant
NC Facility ID 1200107
Inspection Report County/FIPS: Burke/023
Date: 02/18/2022
Facility Data Permit Data
Valdese Weavers, LLC -Lovelady Road Plant Permit 09762/R03
705 Lovelady Road,NE Issued 3/2/2017
Valdese,NC 28690 Expires 2/28/2025
Lat: 35d 45.7562m Long: 81 d 32.6161 m Class/Status Synthetic Minor
SIC: 2269/Finishing Plants,Nec Permit Status Active
NAICS: 313312/Textile and Fabric Finishing(except Broadwoven Fabric)Mills Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Scott McLaughlin Roger Berrier Scott McLaughlin NSPS: Subpart Dc
Facility Engineer Chief Operating Officer Facility Engineer
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 02/16/2022
Inspector's Name Mamie Colburn
Inspector's Signature: (� Operating Status Operating
Compliance Status Compliance- inspection
/�� Action Code FCE
Date of Signature: /�q Inspection Result Deficiency
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2015 7.84 0.0100 2.26 0.5700 1.90 5.14 944.70
2011 7.83 0.0100 2.29 0.6100 2.09 7.83 967.50
* 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

Valdese Weavers,LLC—Lovelady; 2
1. Directions
A. Take I-40E to Exit 113 (Rutherford College). Turn left. Go approximately 2 miles and turn
left onto Lovelady Road. Proceed approximately one mile, and the facility will be located on
the right. Inspectors may need to check in or meet at the Plant No. 1 at 1000 Perkins Road,
S.E. first.
2. Facility Overview
A. Safely: Hearing Protection and Safety Shoes. Safety Issue: Forklifts travel throughout the
facility; vision of forklift drivers may be limited due to equipment and storage of items. Care
should be taken when touring the facility. The roof of the facility can be accessed by stairs.
B. Contact Information: I reviewed the contact information with Mr. Scott McLaughlin from the
IBEAM FacFinder report. The invoice contact needed to be updated and was updated upon
return to the office. It should be noted that Mr.McLaughlin's office is located at Valdese
Weavers Perkins Road facility,not at this facility. Mr. Laughlin's direct line is(828)893-
4130 and cell phone is 828-289-9426. Mr. Phil Eller,Plant Engineer for the Lovelady and
Crescent Street plants is the back-up contact for this site should Mr.McLaughlin not be
available. He can be reached at(828)432-4244. Mr. Eller may be the lead for plant floor
access.
C. Facility Overview:
a. Process Overview: Valdese Weavers, Inc. has three permitted facilities in Burke
County, along with one unpermitted weaving plant in Hildebran. The company
makes upholstered material for the furniture industry. The Lovelady Road plant is the
company's finishing and distribution center. The Crescent Street plant is considered
the"Prep Plant",where all warping and slashing will be done. The Perkins Road
facility conducts weaving and dyeing. As part of its process,this facility has the
following permitted equipment: three natural gas/No. 2 fuel oil-fired boilers,and
three natural gas-fired tenter frames.
b. The facility operates 3 shifts, 24 hours per day,Monday-Friday,with an occasional
Saturday or Sunday.
c. This site has approximately 260 employees including office staff.
d. Production is steady throughout the year and does not have major seasonal changes.
3. Emissions Source Observations
Inspection Narrative: On Wednesday February 16,2022,I arrived at the 1000 Perkins Rd. facility
and met with Mr. Scott McLaughlin and Mr.Phil Eller. We spoke in a conference room before
touring Plant No. 1 and then the Lovelady facility. Around 12:45 pm, after finishing the Plant
No. 1 tour I drove approximately 3 miles to the Lovelady facility.As I was arriving on Lovelady
Rd. I saw obvious visible emissions from the roof of the Lovelady plant. I inquired about these
when I got to the parking lot and met with Mr. Eller. We then proceeded to the roof to view the
source of the emissions.
After investigating the roof,we went into the facility and spoke with various members of the
production team regarding the emissions.After those discussions, I proceeded with the rest of the
planned inspection. Then, I spoke the Mr.McLaughlin on the phone, and he came out to the
Lovelady facility. We both observed the visible emissions from the tenter frames and discussed
the applicable opacity limit for the tenter frames. I left the facility at 3:45 pm.
A. The following permitted equipment was observed during inspection:

Valdese Weavers, LLC—Lovelady; 3
..___ ..... ................ .... .._..
Emission Emission Source Control Facilities Observations
System most recent
Source ID Description Today 2/16/2022
ID inspection
...... .
July 21, In operation firing
B1 (NSPS) natural gas/No. 2 fuel oil-fired boilers N/A 2021 on natural gas. See
(33.5 million Btu per hour maximum details below on
heat input rate,each) boiler specs.
natural gas/No 2. Fuel oil-fired boiler Unknown Observed out of
B2 (NSPS) (33.5 million Btu hr. maximum heat N/A
input rate) service permanently.
natural gas/No 2. Fuel oil-fired boiler Unknown Observed out of
B3 (NSPS) (33.5 million Btu hr.maximum heat N/A
input rate) service permanently.
........ .... ........ .. . ....
one natural gas-fired tenter frame (8.4 June 29, In operation.No
TF 1 million Btu per hour maximum heat N/A 2021 visible emissions.
input rate). 10 zone. Adding heat only.
221 OF.
......... . . . ........ ...... _....... .. ......... . .................................................
June 29, In operation. Visible
2021 Emissions
one natural gas-fired tenter frame(6.0 estimated to be
TF2 million Btu per hour maximum heat N/�' above 20% opacity.
input rate)6 zone. See details below.
........................................ ................................... ......... ......... ......... ......... .. . ...... ........ ........
:Adding latex.240 °F
June 29, In operation. Visible
one natural gas-fired tenter frame(7.0 2021 emissions estimated
TF3 million BTU per hour maximum heat „ N/A to be near 10%
input) 8 zone. opacity. Adding
latex.231 OF.
....................... ................................................ ...........................................................................................................................................................................................................................................................................................................................................
Boiler observations:
Boiler#1 (ID No. B 1)—In operation running on natural gas.New natural gas burner retrofit was
observed.Natural gas usage logs were reviewed. According to records reviewed during this inspection,
the last inspection and maintenance of Boiler#1 was on July 21, 2021. This 800 HP, fire-tube boiler is
operated regularly at 50% capacity. It is used for 90%comfort heat and 10% process heat. The set point
for steam pressure is 50 psi,46 psi observed today. The boiler stack temp goal is 300 OF,with 280 OF
observed today. Serial number is 11192, with a manufacture date of 1991.The boiler appeared to be
operating properly
Tenter Frames Zones and Temperature Observations:
Each of the tenter frames have a series of zones. Each of the zones may have a different operating
temperature. These temperatures vary depending on the fabric and the product being applied to the fabric.
• TF 41 was in operation. It has a current set point of 225°F and was operating at 211 OF. It has
10 zones. I observed that there were no visible emissions at the time of this inspection. Process
was only adding heat(no treatment or coating was being applied).
• TF 42 was in operation. It has a current set point of 240 OF and was operating at 240 OF. It has 6
zones. Visible emissions were estimated to be above 20%. Process was adding Latex and heat.

Valdese Weavers, LLC—Lovelady; 4
• TF#3 was in operation. It has a current set point of 179 °F and was operating at 231 °F
(operating above set point per Mr. Eller for unknown reason). It has 8 zones. Visible
emissions were estimated to have an opacity below 20%. Process was adding Latex and heat.
B. VE Observations. Relatively high visible emissions were noted upon arrival from Lovelady
Rd. Those emissions appeared to be coming from the center area of the roof and appeared to
exceed 20% opacity. Some visible emissions (VE)were estimated to be closer to 50%
opacity. The VE was first observed upon arrival at 12:45 pm. Immediately after seeing these
emissions, I went onto the roof with Phil Eller to observe the source of the visible emissions.
At that time the emissions were white and appeared to be coming from the middle set of
tenter frame stacks. These stacks emit from Tenter Frame#2 (ID No. TF2)per Mr. Eller.
Mr. Eller and I left the roof to view the current process going on inside at the Tenter Frame
#2. I spoke to the new plant manager, Lisa Campbell. She stated that the current process in
the tenter frame was a common process of pushing a Latex product into woven fabric. The
process solution is called"Dicey Backing 5". I observed the process temperatures and set
points which are documented the in the previous section. We discussed the possible causes of
the emissions and cleaning schedules. Ms. Campbell was not aware of the stack's current
opacity or the opacity limit.
Mr. Eller stated that Tenter Frame#2 requires a faster start up and shut down to get it to the
correct temperatures. It was currently operating at the set point of 240 'F. Tenter Frame#3
increases in temperature slower and decreases in temperature slower and was operating below
it's set point, moving towards a higher temperature.
I inquired about the most recent cleaning and inspection of the three tenter frame stacks. Per
their internal computer system,the last time cleaning was documented was June 29, 2021.
Mr. Eller and other's believed additional cleanings had occurred since then. We then spoke to
Miaky Ayala, finishing manager. Mr. Ayala stated that the last time the stacks were cleaned
was at least two months ago. He stated that the plant was short staffed and did not have the
personnel to clean this prior. We discussed the situation and he offered that the stacks would
be cleaned as soon as possible, by this weekend at the latest.
After completing the rest of the inspection, I spoke to Mr. McLaughlin, and he met me on
Lovelady Rd. to view the visible emissions. At that time (3:30 pm)visible emissions were
still consistently coming from the stacks. Mr. McLaughlin stated that he would be working to
address the issue as soon as possible. I stated that I would follow up with him the next day
and did so. I called the compliance coordinator and manager on duty to discuss the situation.
VE Summary: Visible emissions with relatively high opacity were seen from Tenter Frame
#2 two exhaust stacks. A Method 9 was not completed because weather conditions made
objective evaluation of opacity difficult. Possible causes, such as process temperatures,
product type,process fan settings, and reduced frequency of exhaust stack cleaning were
discussed with Mr. Eller and Mr. McLaughlin. The facility personnel appeared to understand
the issue and started investigating the cause and resolution while I was on site. Previous
visible emissions from the tenter frames were noted during an inspection in 2018.
Documentation from this event was shared with Mr. McLaughlin via email on 2/17/21.

Valdese Weavers, LLC—Lovelady; 5
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Valdese Weavers, LLC—Lovelady; 6
Photo of Valdese Weavers Lovelady Plant 2/16/22. Center two stacks are from tenter frame
#2. Taken by Mamie Colburn at 12:30 pm.
C. Ductwork observations -No noticeable holes or structural issues in emissions ductwork were
noted during this inspection.No leaks into interior of building seen.No haze or fog inside the
building seen.
D. Insignificant Exempt Activities:
................................. ....... ........ . . . ...... . ...... ......_.... ......... ......._ . .......................................... .. ......_. .... ........_ ...._..... ... ..........................................................
Source Today's Observations
........ ........... ......................................... ....... ......... .. ..... ... .......... ............ .......... .......................................................... ...........
I-Cal - one natural gas-fired calendar process This item has been removed from the facility. It is
(0.19 mmBtu/hour maximum heat input rate) no longer on site.
....... ......... .. .................. .............. ....... ... ....
Two dryers observed not in operation. According to
facility personnel,the dryers are currently not used
I-Dry - five natural gas-fired dryers(2.81 very often. Some will be sold.
mmBtu/hour maximum heat input rate, A new Biancalani natural gas-fired dryer was
combined) added to the floor to replace the other dryers.
This dryer was in operation at 110 T. No
visible emissions seen.
......... ......... .. ..... .... ..... ......... ....._ ......... .......... ...... .......... .............................................................
The storage and mixing room was not observed. I-
Mix was added to the insignificant/exempt
I-Mix—one chemical storage and mixing room
activities list during the recent permit renewal. The
facility now has a designated storage and mixing
room for all the chemicals used on site. The
facility calls this room the Finishing Drug Room.
.....
4. Regulatory and Permit Condition Review
A.
a. Specific Condition#3: 2D .0503 "Particulates from Fuel Burning Indirect Heat
Exchangers" - Particulate emission limited to 0.33 lb./MMBtu for Boilers B 1, B2
and B3.No visible emissions seen from the boilers and No. 2 fuel not used.
Compliance indicated.
b. Specific Condition#4: 2D .0515 "Particulates from Miscellaneous Industrial
Processes" - Particulate control requirement: Permit states tenter frames"shall not
exceed allowable emission rates."Potential compliance issue noted.
c. Specific Condition#5: 2D .0516 "Sulfur Dioxide Emissions from Combustion
Sources," sulfur dioxide emissions from combustion units shall not exceed 2.3
pounds per MMBtu. Boilers operating on natural gas. Compliance indicated.
d. Specific Condition 6: Visible Emissions Control Requirement. All equipment at
this facility has a 20% opacity limitation. Visible emissions were viewed today
from tenter frame#2, approximated to be in the 20-50% opacity range. Method 9

Valdese Weavers, LLC—Lovelady; 7
was not completed. See section above for full discussion. The facility has
previously had visible emission issues from the tenter Frames. After receiving an
informational letter concerning visible emissions from TF1 in 2018,the facility has
increased the frequency of cleaning all the TF stacks from bi-monthly to weekly.
During this inspection stacks had not been cleaned in at least 2 months. Compliance
issue noted during this inspection. See discussion in Section 3B regarding VE
observations.
e. Specific Condition 7: New Source Performance Standards. The three permitted
boilers at this facility are subject to NSPS Subpart Dc. As such,the facility is
required to keep track of each fuel combusted in the boilers, along with fuel supplier
certifications that show sulfur content of the fuel oil to be less than 0.5% by weight.
The fuel records (natural gas)were reviewed. According to Mr. Eller, no fuel oil
has been burned at the facility since Valdese Weavers bought it in 2007.NSPS
reporting requirements are up to date. Compliance is indicated.
f. Specific Conditions 8: Excess Emissions Notification Requirement. The facility
is required to report excessive emissions that last for four hours and that result from
a malfunction, breakdown of process or control equipment or any other abnormal
conditions. The facility states they were unaware of any excessive emissions event.
Potential issue noted during inspection. No opacity observations regularly are
made by facility staff.
g. Specific Conditions 9: Fugitive Dust Control Requirement. The facility cannot
cause or allow fugitive dust emissions to cause or contribute to substantive
complaints or excess visible emissions beyond the property boundary. During
inspection,no fugitive dust emissions were observed. All lots are paved.
Compliance is indicated.
h. Specific Conditions 10: Toxic Air Pollutant Emissions and Reporting
Requirement. Valdese Weavers LLC-Lovelady Road Plant has facility wide hourly
emissions limits for ammonia(as NH3)and formaldehyde. The DAQ approved
modeling, submitted by the facility, on September 22,2008. The facility is required
to be constructed and operated in a manner consistent with the approved computer
modeling. The facility appears to be operating consistent with the approved
modeling Compliance is indicated.
i. Specific Condition 12: 40 CFR 63 Subpart JJJJJJ-National Emission
Standards for Hazardous Air Pollutants for Area Sources: Industrial,
Commercial,and Institutional Boilers. The facility has indicated the primary
operating scenarios (POS)for the affected sources is firing natural gas(ID Nos. B 1,
B2, and B3). The facility is not required to comply with most of the JJJJJJ
requirements if they continue to burn natural gas. Once the facility begins to burn
fuel oil,they will be required to comply with the JJJJJJ requirement. The facility
has no plans to burn fuel oil, only natural gas. There is currently no fuel oil stored
on site. Boiler natural gas logbook was reviewed. The facility is required to record
monthly and total annually the gallons of fuel oil combusted and a fuel supplier's
certification shall be kept onsite and made available to DAQ personnel on request.
The facility is not currently burning No. 2 fuel oil. There is no No.2 fuel oil stored
on site. The facility has not burned any No.2 fuel oil since 2007. Compliance is
indicated.

Valdese Weavers, LLC—Lovelady; 8
B. Reporting Requirements: The facility is required to submit an annual report to the DAQ by
January 30 of each year regardless of actual emissions. The report should contain the
following information:
A. amount of fuel oil combusted, facility-wide
B. a copy of the fuel supplier certification with the highest sulfur content delivered to the
facility within the previous calendar year.
The facility is required to submit a semi-annual report to the DAQ. The report should contain
the following information:
A. the name of the oil supplier
B. a statement from the oil supplier that the oil complies with the specification under the
definition of distillate oil and
C. a certified statement signed by the owner or operator of an affected source that the
records of fuel supplier certification submitted represent all of the fuel combusted during
the reporting period.
No fuel oil is used at this facility. The most recent fuel oil usage report was received on 1/13/22
with statement of no fuel used during the reporting period.Records reporting compliance is
indicated.
5. Compliance History Review: Five-Year Compliance History. The facility has had no
documented violations in the past five-years. A letter addressing visible emissions from the
tenter frames was sent to the facility on May 8, 2018. At that time visible emissions were
estimated to be in excess of 60%were suspected from the tenter frames. Adjustments to the fan
speed and other process engineering brought those emissions down below 20% during the visit.
In the written response received on May 21, 2018,the Permittee states they are working with
material suppliers to identify a possible cause of the VE,while also contacting a consultant to
explore possible solutions to address the issue.
6. Stack Test Review: Valdese Weavers, LLC-Lovelady Road Plant currently does not have a
stack test requirement in their air permit. No stack test has been performed since the last
inspection.
7. 112r Review: Valdese Weavers, LLC - Lovelady Road Plant is subject to the 112(r)-program
general duty clause but does not maintain regulated chemicals onsite above the threshold
quantities, which would require a risk management plan.
8. Compliance Assistance: Assistance addressing visible emissions from the tenter frames is
indicated. At the conclusion of my inspection on 2/16/22 1 met with Mr. McLaughlin to explain
and outline the observed opacity issue. On 2/17/22 a follow up email was sent to Mr.
McLaughlin. In his response on the same day, he stated that the tenter frame stacks were cooled
and cleaned overnight. Additional compliance assistance and communication is ongoing.
9. Conclusion/Compliance Statement: At the time of inspection,Valdese Weavers—Lovelady
Road facility appears to be in compliance for Air Permit 09762R03. However, potential
compliance issues with regard to visible emissions from Tenter Frame TF-2 were noted.
Ongoing,short-term compliance improvement is being closely tracked. A follow-up letter
will be issued summarizing findings and requesting additional information regarding the
Permittee's efforts to reduce visible emissions from this process.