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Home My WebLink AboutAQ_F_0100301_20210603_CMPL_CAV-Rpt (4) NORTH CAROLINA DIVISION OF Winston-Salem Regional Office AIR QUALITY Cintas Graham NC Facility ID 0100301 Inspection Report County/FIPS:Alamance/001 Date: 06/04/2021 Facility Data Permit Data Cintas Graham Permit n/a 610 Woody Drive Issued n/a Graham,NC 27253 Expires n/a Lat: 36d 3.5140m Long: 79d 23.1276m Class/Status: Registered SIC: 7218/Industrial Launderers Permit Status: Inactive NAICS: 812332/Industrial Launderers Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Steve Whitley Justin Kluttz Lisa Autrey Plant Manager General Manager Chemical/Environmental (336)228-0531 (336)494-7224 Engineer (513)965-4964 Compliance Data Comments: Inspection Date: 06/03/2021 Inspector's Name:Thomas Gray Inspector's Signature: 140w�,✓, DMM Operating Status: Operating Compliance Status: Compliance-inspection Action Code FCE Date of Signature: OrO Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2014 1.55 0.0051 0.8700 23.76 0.7300 1.55 2411.39 *Highest HAP Emitted in ounds 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 Introduction: On June 3,2021,Mr.Thomas Gray,Environmental Specialist I,of the Winston Salem Regional Office-Division of Air Quality (WSRO-DAQ),contacted Mr. Steve Whitley,Plant Manager of Cintas Graham,for the purpose of conducting an announced compliance assurance visit(CAV). Due to COVID-19 concerns,Mr.Gray last conducted a partial compliance evaluation(PCE)via telephone with Mr. Whitley on April 14,2020.The facility was found to be operating in compliance with all applicable rules and regulations at that time.The facility launders linens,towels,and uniforms for multiple private companies.The WSRO-DAQ received a registration application from the facility on January 22,2019. Upon review of the application,it was determined the facility qualified for registration,as the facility-wide actual total aggregate emissions of PM10, S02,NOx,VOCs,CO,HAPs,and TAPs were more than 5TPY and less than 25TPY for the 2018CY.The facility's previous Air Quality Permit No. 10 14 1 R04 was officially rescinded,and Registration No.0100301X00 was officially issued on April 18,2019.Mr. Whitley confirmed the facility's typical hours of operation are Monday-Friday,from 5:00 a.m.to 2:30 p.m.for 50 weeks out of the year.All contact information as listed in IBEAM was verified as correct,with no changes necessary at the time of the visit. Safety: The required PPE at the facility consists of the following: safety shoes,safety glasses,ear plugs.Inspectors should be aware of the moving low hanging hooks in the facility. Applicable Regulations: 2D.0202—Registration of Air Pollution Sources 2D.0503—Particulates from Fuel Burning Indirect Heat Exchangers 2D.0515—Particulates from Miscellaneous Industrial Processes 2D.0516—Sulfur Dioxide Emissions from Combustion Sources 2D.0521—Control of Visible Emissions 2D.0535—Notification Requirement 2D .0540—Particulates from Fugitive Dust Emission Sources 2D.1806—Control and Prohibition of Odorous Emissions This facility is not required to implement a Subpart 112(r)risk management plan(RMP)in accordance with federal regulation 40 CFR 68,because they do not purchase,produce,use or store any of the regulated chemicals in quantities above their corresponding threshold limits. However,the facility is subject to the General Duty clause contained in this rule. Discussion: This facility launders a variety of textiles products that it rents to customers including uniforms,wet mops,bar towels,mats,and shop towels(<10%of total throughput).It is very important to note that this facility no longer accepts ot'processes any print or furniture towels at this facility due to their high residual solvent content.The general process at the facility is the following: Laundry is sorted as it is unloaded from the trucks in the unloading area.Once sorted,the laundry is then transferred to the'wash-alley to be washed in one of eight industrial wash machines using water and detergent.After washing,the laundry is then transferred to one of five industrial driers for drying.Following drying,the laundry is hung and conveyed on hooks through the natural gas-fired steam tunnel. The facility operates a natural gas fired boiler which provides the steam for this tunnel.Following the steam treatment,the laundry is then pressed and sorted.During the CAV,Mr. Gray observed all eight industrial washers(six large and two small),the five-natural gas-fired industrial driers,and the natural gas-fired boiler in operation with no visible emissions, indicating likely compliance with 2D.0521.Mr.Whitley stated the boiler is tuned up semi-annually and is only capable of firing natural gas.The facility also operates a small waste-water treatment plant(WWTP)which was observed by Mr. Gray during the visit. Wash and rinse water from the washing machines are discharged into trenches in the wash alley and transported to the WWTP for treatment before discharge.No other equipment or process changes have occurred at the facility since the previous visit.The facility processed approximately 5,477,783 lbs.of laundry for the 2020CY. Applicable Regulations Explained: 2D.0503-Particulates from Fuel Burning Indirect Heat Exchangers This rule applies to installations in which fuel is burned for producing heat or power by indirect heat transfer.Fuels include those such as coal,coke,lignite,peat,natural gas,and fuel oils,but exclude wood and refuse not burned as a fuel. When any refuse,products,or by-products of a manufacturing process are burned as a fuel rather than refuse,or in conjunction with any fuel,this allowable emission limit shall apply.The facility's two(2)natural gas-fired industrial dryers(2.5 million Btu/hr max heat input,each),the two(2)natural gas-fired industrial dryers(0.30 million Btu/hr max heat input,each),the natural gas-fired industrial dryer(2.8 million Btu/hr max heat input),and the natural gas-fired boiler(16.738 million Btu per hour max heat input)are subject to this regulation. The emission limits and heat inputs were calculated as provided in the table below in a previous permit review R03 (Taylor Hartsfield,WSRO Environmental Engineer).For the four smaller dryers and boiler,the emission limit is 0.487 lbs./MMBtu,and for the larger dryer,the emission limit is 0.472 lbs./MMBtu. Compliance with 2D.0503 is indicated. Table 3-Particulates from Fuel Burning Indirect Heat Exchangers daaI Heat ...CapacityNEBti�r/hr] [1VBtu/hr] ', [Ibs'PM/MMBtu] '; ES-DRYERI Pre Ma 20 2013 2.5 22.3a 0.487 ES-DRYER2 Pre May 20,2013 2.5 , 0.4871 �. _. ,.. 22 3a ..mr..............................................._.._................................._.__..........._.............._..y.................................__.............. _....... ES-DRYER3 Pre May 20,2013 .......................................0 3 22.3a 0.4871 ES-DRYER4 Pre May 20,2013 22.3a 0.4871 IES-B 1 Pre May 20,2013 16.7 22.3a 0.487 ................... . . ( 0.472ES-DRYER5 -FPosMy0,2013 2.8 25.1° ....................._..............._..........._.._......__._...................................... .........................................."...........�_....��..._...... ..........�......,_...�... Q=2.5+2.5+0.3+0.3+ 16.7+2.8=25.1 =2.5+2.5+0.3+0.3+16.7_22.3 b E=1.09 x 22.3-0.2594=0.487 a E=1.09 x 25 1 o.as9a=0.472 Actual particulate matter emissions are equal to 0.0075 pounds per million Btu,based on an AP-42 Table 1.4-2 for natural gas. The equation assumes the average heating value of natural gas is 1,020 Btu/scf. Compliance with this condition is demonstrated. 2D.0515-Particulates from Miscellaneous Industrial Processes This regulation sets a maximum rate for PM emissions from stacks,vents,or outlets resulting from industrial processes for which no other emissions control standards are applicable.The formulas that calculate the maximum amount of particulate emissions are as follows: If P<30 tons/hr: E=4.10(P)o.6� If P>30 tons/hr:E=55.0(P)°11-40 Where:E=Maximum allowable emission rate for particulate matter(lb/hr) P=Process rate(tons/hr) The facility's natural gas-fired drying equipment is subject to this rule.The facility performed calculations to show compliance with the rule based off of a worst-case scenario on the three different kinds of dryers that they currently have on-site using a worst-case PM emission rate of 1.35 x 10'pounds of PM per pound of clean textile which was obtained from a stack test at another Cintas facility. All of the dryers are equipped with lint filters to control PM emissions,but are considered to be integral to the dryers according to the facility,therefore they will not be listed on the registration.The following table provided below summarizes the maximum textile rate, as well as the allowable and actual PM emissions for each different dryer type. Maximum textile rate Allowable PM emissions Actual PM emissions Dryer type ton/hr Ibs/hr lbs/hr Type 1 660 lb load 0.66 3.1 1.70 Type 2 700 lb load 0.7 3.23 1.81 Pon e 125 lb load 0.125 1.02 0.32 According to calculations provided above from the rescission review(Hunter Johnson,Engineer,2019),compliance with 2D.0515 is indicated. 2D.0516-Sulfur Dioxide Emissions from Combustion Sources This regulation limits emissions of sulfur dioxide from any source of combustion that is discharged from any vent,stack,or chimney and shall not exceed 2.3 pounds of sulfur dioxide per million BTU heat input.This requirement applies to the facility's two(2)natural gas-fired industrial dryers(2.5 million Btu/hr max heat input,each),the two(2)natural gas-fired industrial dryers(0.30 million Btu/hr max heat input,each),the natural gas-fired industrial dryer(2.8 million Btu/hr max heat input),the natural gas-fired boiler,and the natural gas,direct-fired steam tunnel.According to permit review R03 (Taylor Hartsfield,Engineer)the S02 emissions are S02(Natural Gas)=0.00059 lbs. S02/MMBtu.All of the emissions are below the 2.3 lbs. S02/MMBtu threshold.Continued compliance with 21) .0516 is anticipated. 2D.0521-Control of Visible Emissions According to this rule,this facility is limited to 20%opacity when averaged over a six-minute period for sources manufactured after July 1, 1971,and 40%opacity for sources manufactured as of July 1, 1971,when averaged over a six-minute period.No visible emissions were noted during the CAV indicating likely compliance with 2D .0521. 2D.0535-Excess Emissions Reporting and Malfunctions According to this rule,this facility must notify the DAQ of any excess emissions lasting longer than four hours in duration resulting from a malfunction,breakdown of process or control equipment or any other abnormal conditions.Mr. Whitley indicated that there have not been any malfunctions nor is the WSRO-DAQ aware of any instances, indicating likely compliance with 2D .0535. 2D.0540-Particulates from Fugitive Dust Emission Sources According to this rule,the facility shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints, visible emissions,or allow fugitive dust beyond their property boundary.Due to the paved nature of this facility,fugitive dust is highly unlikely.Compliance with 2D .0540 is indicated. 2D.1806-Control and Prohibition of Odorous Emissions According to this rule,the facility must implement management practices that prevent odorous emissions from the facility from causing objectionable odors beyond the facility's boundary.No odors were encountered during the CAV.Compliance with 2D .1806 is likely. Facility-Wide Emissions: _ .... E . Oo CY2 P 018) 'ollutant otentialEmissions mi f .. Mons/yr1 .. �. .... �toris/yx PM .............:.....:.:............... ............. .............. .......:.............:..:......:... 1.20 12.19 .w.._.w.......w._._........_,,...w_..................PM�°........... ....... ...,..__.........._..............,...., .....,. ._.._._......, ..................... ......_....... ........._.................. .w........... ............ ._...... _.,w.._,...__....._...,..... � ,.._............,......,._............._.......,,.........._..................... ....... ...........w...........__.._.___...........,......_......_ NO, �� 0.67 � 11.44 :..... .......:...........:...:. _. :. . ......... ................I................ CO 0.56 9.61 �W..._W_......_..._.�.....�,,---.....-._._._.._._.� ............_.._............_..._............w.........................._......_..............._._.._.................................._._................._..........._....�............_..........................................................................._................:........................................................................................................................_...... ..,...................... VOC 2.20 92.09 .� F_m �6 HAPTocal 39 _... .m _. _._...�..,_.._... ._. _ . .��, 16 69 M.._� ._... ..__. Registration Status: No changes in emission sources,facility-wide emissions or production rates have occurred at this facility that would otherwise affect the current registration status of this facility. Stack Testing: No testing has been performed at this facility. NSPS/NESHAP Applicability: This facility is currently not subject to any NSPS/NESHAP standards or regulations. Conclusion: The facility appeared to be operating in compliance with all applicable air quality standards and regulations at the time of the CAV.