AQ_F_1400075_20210420_CMPL_CAV-Rpt

ILA '75- - CA
NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Shuford Yarns, LLC,Dudley Shoals Plant
NC Facility ID 1400075
Compliance Assurance Visit(CAV)Report County/FIPS: Caldwell/027
Date: 04/21/2021
Facility Data Permit Data
Shuford Yarns,LLC,Dudley Shoals Plant Permit n/a
5100 Burns Road Issued n/a
Granite Falls,NC 28630 Expires n/a
Lat: 35d 51.8610m Long: 81 d 22.4400m Class/Status Registered
SIC: 2281 /Yarn Mills,Except Wool Permit Status Inactive
NAICS: 313111 /Yarn Spinning Mills Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Beth Anderson Khalid Majeed Beth Anderson
Director of EHS Vice President of Director of EHS
[phone] Manufacturing [phone]
Ext.4222 [phone] Ext.4222
Compliance Data
Comments:
CAV Date 04/20/2021
Inspector's Name Bob Graves
Inspector's Signature: Operating Status Operating
Compliance Status Compliance—procedural
requirements
Date of Signature: J Action Code FCE
�— 2 I CAV Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2014 3.90 --- --- 0.3500 --- 1.95 ---
2009 2.86 --- --- 0.3500 --- 1.43 ---
Highest HAP Emitted(in pounds)
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
Location: Shuford Yarns,LLC, Dudley Shoals Plant is located at 5100 Burns Rd in Granite Falls,NC,
Caldwell County.

Directions:
From Lenoir,Travel South on Hwy 321A to downtown Granite Falls and turn left onto Dudley Street
(immediately before the town square (or triangle). At some point(probable when you go under Hwy 321)
this road turns into Dudley Shoals Road. Travel for a about 6 miles and turn left onto Burns Road(just
before a bridge). The facility will be just ahead on the right. NOTE: RECOMMEND USING PHONE
OR GARMIN UNIT FOR DIRECTIONS TO THE FACITY.
Safety:
Safety shoes,hearing and eye protection. NO JEWELRY.
Description:
Shuford Yarns, LLC,Dudley Shoals Plant is a textile plant that produces yarn for the textile industry.
This facility is a Registered Facility as of November 22, 2016. Air Registration No. 1400075x00 replaces
Air Permit 07392G06. The facility operates 3 shifts, 5 days a week and employees 100 employees
including office staff. The facility will operate on weekends, if needed. The phone number for the site is
828-396-2342.
Process Description:
Bales of rayon, acrylic, and polyester are used to make the yarn. The bales are opened and fed into a
machine that separates the fibers. The fibers are then blown into a card machine that aligns the fibers.
There are 32 card machines. Each machine is able to process approximately 300 pounds of fiber per
hour. Exhaust from the card machines are vented to one of two bagfilters that vent to the roof. Next,the
fiber is drawn into rope,which is called sliver. The rope will be combined with other rope in a 6:1,or 8:1
ratio to form one large rope. The rope will be formed into yarn by one of three methods. The first
method, and slowest, is roving. Roving is defined as a continuous slightly twisted strand of cotton fibers
which has not received its final drawing. This definition is universally accepted. Roving is also
distinguished as the first process in which material is wound on a bobbin. These roving bobbins are
reeled on the ring spinning frames for spinning yarn. The rope is fed into a roving machine that draws out
the fiber and adds a twist to form the yarn. The next method is spinning. Spinning can be done two
ways. The first is called air jet open-end spinning. This is a spinning system in which sliver feedstock is
highly drafted, ideally to individual fiber state, and thus creates an open end or break in the fiber flow.
The fibers are subsequently assembled on the end of a rotating yarn and twisted in. The last method is
called ring spinning. This is a yarn spinning method in which roving(a thin strand of fiber with very
little twist)is fed to a"traveler" which rotates around the edge of a ring. Inside the ring is a faster
rotating bobbin. The process simultaneously twists the roving into yarn and winds it around the bobbin.
Ring spun yarns are generally stronger than open-end yarns. The facility's main product is yarns used in
firehose jackets.
Site Visit Summary: Inspection Narrative
On April 20,2021, I traveled to the Shuford Yarns, LLC, Dudley Shoals Plant, and made an
off-site,unannounced observation of the facility. The facility appeared to be in operation.
No VE or fugitive dust was observed from the facility.No objectionable odor was detected.
Due to the COVID- 19 Pandemic, DAQ staff are not physically going inside facilities to
perform inspections.
On April 22,2021, at approximately 12:48pm, I called Ms. Beth Anderson, Director of EHS.
Based on my conversation with Ms. Anderson, we discussed the following: FACFINDER
contacts are correct as listed. Ms. Anderson and I discussed if there were any recent changes
and/or planned changes at the facility. Based on my conversation with him, we discussed the
following:

a) Verified the contacts based on FACFINDER printout. All contact information is
current and addresses are correct.
b) Mr.Mike Bradshaw,Plant Manager,would be the back-up facility contact for this
site should Ms. Beth Anderson be unavailable. No changes or updates need to be
made to the process and equipment descriptions.
c) Angela Hopper's last inspection was conducted on July 24, 2019.
Permit Exemption:
It appears that the facility is eligible to be exempt entirely from air permitting requirements since all air
emission sources are vented inside the building and the boiler is no longer operated.
Emiss o i Source description Contr+ System Mkr pti6n
air filtration system the s)on -
yarn spinning mill process N/A
The air filtration system(s)on the yarn spinning mill process was observed in operation with no visible
emissions. All the bagfilters at the facility are vented inside the facility.
The combustion equipment firing No. 2 fuel oil/natural gas with a combined total maximum heat input
not to exceed 45 million Btu per hour is on site but no longer operational. There is no fuel tank for this
equipment on site. According to facility personnel,there are no plans to replace this equipment.
Specified Conditions and Limitations:
1. Registration Criteria: Pursuant to 15A NCAC 2D .0202"Registration of Air Pollution Sources,"
and 15A NCAC 2Q .0102(e), as requested by the Registrant,the facility-wide actual total
aggregate emissions of particulate matter(PM 10), sulfur dioxide, nitrogen oxides,volatile
organic compounds, carbon monoxide,hazardous air pollutants, and toxic air pollutants shall be
less than 25 tons per year. Registration shall not apply to any facility as follows:
a. synthetic minor facilities that are subject to Rule 15A NCAC 2Q .0315;
b. facilities with a source subject to maximum achievable control technology under 40 CFR
Part 63;
c. facilities with sources of volatile organic compounds or nitrogen oxides that are located
in a nonattainment area; or
d. facilities with a source subject to NSPS, unless the source is exempted under 15A NCAC
2Q .0102 (g) or(h).
The facility continues to meet the criteria for being classified as a registered facility.
2. Record Keeping: (15A NCAC 2D .0202) -The Registrant shall maintain records on site to
establish that facility-wide annual air pollutant emissions remain below the 25 ton per year
threshold level listed above. Records (in written or electronic format) shall be maintained for a
minimum of two years and made available to DAQ personnel upon request.
The facility is maintaining records on site documenting facility-wide emissions. The facility
is no longer required to submit an annual production report; however,the facility continues
to submit an annual report. Compliance is indicated.

3. Notification Requirements: (15A NCAC 2D .0202) -The Registrant shall notify DAQ as soon as
possible of the following occurrences:
a. Process Modifications: modification of the processes from that listed in the"Emissions
Equipment Table."
b. Name/Ownership/Location Change: upon changing the facility name, ownership or
location from that as listed in this Registration.
c. Emissions Increase: if facility emissions increase such that the 25 ton per year emission
threshold would be expected to be exceeded. The Registrant shall notify DAQ prior to
exceeding this emissions threshold.
There have been no changes made since the facility became a registered facility.
Compliance is indicated.
4. Department of Environmental Quality Inspections: (NCGS 143-215.3(a)(2))-No Registrant shall
refuse entry or access to any authorized representative of the DEQ who requests entry or access
for purposes of inspection, and who presents appropriate credentials, nor shall any person
obstruct, hamper, or interfere with any such representative while in the process of carrying out his
official duties. Refusal of entry or access may constitute grounds for registration revocation and
assessment of civil penalties.
An off-site visit was made,with no VIE observed. Compliance is indicated.
5. Particulates from Fuel Burning Indirect Heat Exchangers: (15A NCAC 2D .0503)-the allowable
particulate emission rate, "E," in pounds per hour from any stack,vent, or outlet, emitted from
fuel burning indirect heat exchangers shall not exceed the level calculated with the equation
E=1.090 x(Q)-O.1194 for a process rate. "Q"equals the maximum heat input in million Btu/hr.
In the past,the facility operated a boiler with the capability to combust No.2 fuel oil,the
facility no longer operates the boiler. The facility has no plans to replace or operate a
boiler at this site in the future. Compliance is indicated.
6. Particulates from Miscellaneous Industrial Processes: (15A NCAC 2D .0515)-the allowable
particulate emission rate, "E," in pounds per hour from any stack,vent, or outlet,resulting from
industrial processes shall not exceed the level calculated with the equation E=4.1(P)0-61 for a
process rate,P, less than or equal to 30 tons per hour, or E=55.0(P)0.11-40 when P is greater than
30 tons per hour. "P"equals the process rate in tons per hour and includes the weight of all
materials introduced into any specific process that may cause any emission of particulate matter.
In the past,the facility operated a boiler with the capability to combust No.2 fuel oil,the
facility no longer operates the boiler. Compliance is indicated.
7. Sulfur Dioxide Emissions from Combustion Sources: (15A NCAC 2D .0516) -sulfur dioxide
emissions shall not exceed 2.3 pounds per million Btu heat input.
The facility is no longer operating a boiler. Compliance is indicated.

8. Control of Visible Emissions: (15A NCAC 2D .0521)-visible emissions from the emission
sources shall not be more than 20 percent opacity(manufactured after July 1, 1971)or 40 percent
opacity(manufactured before July 1, 1971).
No visible emissions were observed during this visit. Compliance is indicated.
9. Excess Emissions Notification Requirements: (15A NCAC 2D .0535) -the Registrant must report
excess emissions of any regulated pollutant lasting more than four(4)hours, and that result from
a malfunction,to the Division of Air Quality by 9 am of the next working day.
The facility has not had a period of excessive emissions lasting more than more four hours.
Compliance is indicated.
10. Fugitive Dust Control Requirement: (15A NCAC 2D .0540)-the Registrant shall not cause or
allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary.
No fugitive dust was observed during the site visit.
11. National Emissions Standards for Hazardous Air Pollutants: (40 CFR Part 63) -the Registrant
shall comply with all applicable provisions, including the notification,testing, reporting,
recordkeeping, and monitoring requirements promulgated in 40 CFR 63, Subpart JJJJJJ "National
Emission Standards for Hazardous Air Pollutants Area Source Standards for Area Sources that
operate Industrial, Commercial, and/or Institutional Boilers", including Subpart A "General
Provisions."
The facility is not currently operating a boiler and therefore compliance is indicated.
12. Control and Prohibition of Odorous Emissions: (15A NCAC 2D .1806) -the Registrant shall take
suitable measures to prevent odorous emissions from the facility operations from contributing to
objectionable odors beyond the property boundary.
No objectionable odors were observed on site or in the area of the facility. Compliance is
indicated.
Five Year Compliance History:
There have been no documented violations at this facility in the last five years.
Stack Test Review:
The facility has no stack test requirements.
112R Review:
The facility does not appear to be subject to 112R requirements.
Compliance Assistance:
No compliance assistance needed at this time.
Recommendations:
None

Compliance Statement:
Shufford Yarns,LLC,Dudley Shoals Plant was operating in compliance with applicable air quality
regulations at the time of the inspection.