AQ_F_0100204_20210812_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY McComb Industries,LLLP
NC Facility ID 0100204
Inspection Report County/FIPS:Alamance/001
_ Date: 08/12/2021
Facility Data Permit Data
McComb Industries, LLLP Permit 04662/R11
1311 Industry Drive Issued 3/7/2018
Burlington,NC 27215 Expires 7/31/2022
Lat: 36d 3.5160m Long: 79d 26.3640m Class/Status Synthetic Minor
SIC: 2262/Finishing Plants,Synthetics Permit Status Active
NAICS: 313311 /Broadwoven Fabric Finishing Mills Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact
SIP
Tim Kauwell Todd Whitley Danny Crouse
Maintenance Manager President R&D Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 08/12/2021
Inspector's Name Chris Bryant
Inspector's Signature: DMM Operating Status Operating
Compliance Status Compliance- inspection
Action Code FCE
Date of Signature: le llf- 4 i r Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2013 0.9700 0.0100 2.39 1.31 2.00 0.9300 396.00
2008 66.88 0.0200 2.85 2.45 2.39 66.88 990.00
*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
Permitted Sources
..............................................................................................................................................................................................................................................................................................
.....
Emission Emission Source Control i Control System
Source ID Description System ID Description
..._....._................._ W _..r._......r ._....
F-2.1, F 2.2 Four(4)at m ospheric beam tanks N/A N/A
F-2.3, F 2.4 ��_. _. .
.......
...
__...........
....
.....
.........
.................................
.........
.........
__
Natural gas-fired textile finishing oven i
ES-1 (9.0 million Btu per hour maximum CD-1 i Fume eliminator
heat input) I (1,296 square feet of filter area)
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__......_...._..._....................................................._....._...:.:............_............._......._............__........................................................._...........................................r....._......_..._ _.__......._...__..........._....__...._._......._....__._......_.__..._.............. ........ _.._.._._............:..:_
Emission Emission Source Control i Control System
Source ID Description System ID j Description
_ Fume eliminator
ES-2 Hot oil-heated textile fmishing oven CD-2
(1,512 square feet of filter area)
Insignificant/Exem................................ _......... _._T_.............._..........:... ...__... ..:_ . ------. _... ........... ._..........
_ _ .. _._
Source Exemption Source of Source of Title
Regulation TAPs? V Pollutants?
......_........................................_..........._..,......................................._.....................................:.............................._......................................................................................................:.............................................................
I-ES-10-Natural gas/No.2 fuel oil-fired hot oil heater
(7.76 million Btu per hour maximum heat input)
I-ES-30-Natural gas/No.2 fuel oil-fired boiler 2Q .0102 yes Yes
(16.74 million Btu per hour maximum heat input) (h)(1)(A)
I-ES-40-Natural gas/No.2 fuel oil-fired boiler
(16.8 million Btu per hour maximum heat input)
I-ES-5,I-ES-6-Two(2)pressurized dye tanks
2Q .0102
I-ES-11,I-ES-12,I-ES-13,I-ES-14,I-ES-15,I-ES-16,I-ES-17- (g)(14)(B) 7YesYes
Seven(7)pressurized dye machines
........................................._..................._._........._.........................._...__............._.........................._....._.......,..................._.........._�._._.......... ..............._......._. .........._..._..:.._........__................................... _.._.,._.... -
-Underground No.2 fuel oil storage tank(15,000 gallon capacity) 2Q.0102(g)(4) Yes Yes
Introduction
On August 12,2021, Mr. Chris Bryant, Environmental Specialist of the DAQ WSRO, contacted Mr. Tim Kauwell,
Maintenance Manager at McComb Industries,LLLP for an announced targeted compliance inspection. The inspection
was scheduled in advance. Some records such as maintenance records and production data were provided through email.
Mr. Kauwell has been at the company for several years and is very knowledgeable of the processes and emission sources.
The facility was previously inspected on August 21, 2020 by this inspector and was found to be in compliance with DAQ
rules and regulations at that time. The contact information is accurate as reflected in IBEAM. The facility knits, dyes,
and finishes fabrics such as nylon,polyester, and Lycra. These fabrics are manufactured for bed sheets,clothing,pant
bands,and shoe lining. The facility is currently operating one shift(7am-5pm,Monday-Thursday or Tuesday-Friday).
The facility currently has around 60 employees. The 10 hours of production time was referred to by the facility contact as
"pinning"time.
Safety Equipment
Safety shoes, safety glasses,and hearing protection are required equipment when inspecting this facility.
Latitude/Longitude Verifications
The latitude and longitude coordinates were verified to be accurate as documented in IBEAM.
Applicable Regulations
According to Permit Condition A.1 the facility is subject to the following regulations: Title 15A North Carolina
Administrative Code(NCAC), Subchapter 2D .0202, 2D .0503, 2D .0515,2D .0516,2D .0521,2D .0535,2D .0540, 2D
.1806,2Q .0315, and 2Q .0711. This facility is not subject to RMP requirements of the 112(r)program since it does not
use or store any of the regulated chemicals in quantities above the threshold levels in the rule.The facility is only subject
to the General Duty requirements contained in the General Duty Clause.
Discussion
The facility contact, Tim Kauwell (Maintenance Manager),met the inspector and reviewed the air quality regulations as
noted in Permit 04662RI 1. Mr. Kauwell is familiar with the permit and had worked with the former facility contact,John
Small. The facility receives and knits fabrics including nylon,polyester, and Lycra. These fabrics are then dyed and
cured.
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Tenter Frame line 2 (with hot-oil finishing oven,ES-2, and fume eliminator,CD-2)has been completely removed. In
prior years the line was on-site but not operational.
In the first part of the walk-through portion of the inspection,Mr. Kauwell escorted the inspector into the dye house area.
- The seven pressurized dye machines (I-ES-I1 through I-ES 17)were observed. Five were adjacent to each other and the
other two were on the left side. The two pressurized dye tanks(I-ES-5, I-ES-6)were also observed. The two pressured
tanks are referred to by the facility personnel as"atmospheric"tanks. These insignificant sources were not in use during
the inspection. These tanks are inspected yearly by the company to monitor the heat and pressurizing capacities as well as
the structure of the tank itself. The implementation of the dye solutions requires consistent temperatures and pressures to
accommodate the specific fabrics and colors. The polyester material must be introduced to the dye colors at>265°F for a
period of at least 30 minutes. The nylon is dyed at 215°F. This equipment, according to Mr. Kauwell, is used
infrequently.Next,the four atmospheric beam "dip"tanks (F-2.1, F-2.2,F-2.3, F-2.4)were observed. Large spools of
fabric are dunked into the tanks, brought up to 205°F, and additional chemicals are added. This ensures that all the
moisture is forced out of the material. These four tanks were not in use during the inspection. The facility currently only
uses the Natural gas textile finishing oven (ES-1)and the associated fume eliminator(CD-1). The oven operates at a
range of 325-415°F. This finishing oven and control device were in use for a portion of the inspection. Mr. Bryant
observed the visible emissions from the natural gas oven and eliminator immediately upon arrival to the facility. At that
time,visible emissions were between 0-5%opacity, around 10% less than the last two inspections. This improvement
was explained by Mr. Kauwell as because of the maintenance that was performed on the fume eliminator(CD-1)on July
8, 2021. At that time the facility changed the filters, checked the pumps, and removed/replaced the old nozzles.
Previously the facility's maintenance cycles included a nozzle cleaning and not replacement This also included a flush of
the entire unit. Previous inspections on the finishing line and mist eliminator were performed on July 8,2021,January 4,
2021, and July 14, 2020. The maintenance records also documented that"(the) maintenance person drains the CVM every
other day and puts fresh water and new chemicals in the tank." There didn't appear to be any violations of the 20%
opacity limit during the 20 minutes the inspector observed the stack. The emissions from the stack also contain a portion
of water vapor that can make readings somewhat altered. The fume eliminator is a 1985 CVM model that works
somewhat like a mist eliminator. The upper section of this control device contains 16 vertically hung poly mesh tubes that
occupy a"honeycomb" space. Below the tubes, horizontal "blades" spray water across the media to collect the emissions.
The emissions are washed down and collected near the bottom of the eliminator. While the bottom of the eliminator
operates at 250°F,the upper section runs at 115°F. As mentioned earlier,the second finishing line(consisting of the hot-
oil finishing oven,ES-2,and fume eliminator,CD-2),has not been operational for a few years and has now been removed
from the building. The facility may want to consider removing this emission source from the source list when the permit
goes up for renewal if applicable.
The facility has two insignificant/exempt dual fuel (natural gas/No.2 fuel oil)boilers, I-ES-30 and I-ES-40 and one hot oil
heater(I-ES-10) on-site. The dual fuel hot oil heater was operating at 470°F and 46 psi. Units I-ES-30 and I-ES-40
alternate week-to-week and I-ES-30 was on and reading 340°F and 106 psi. These boilers provide steam for the plant and
also for the fire suppression system. The boilers maintenance information is kept by Mr. Kauwell. Also,tune-ups
continue to be performed by Matt Marshall and Company(boiler parts and service) out of Greensboro,NC. Mr. Kauwell
confirmed that the facility has not burned any No. 2 fuel oil in more than 5 years and did not plan on using any in the
future. The facility has an exempt/insignificant underground storage No.2 fuel oil tank that has a 15,000-gallon capacity,
although Mr. Kauwell thought the tank was empty at the time.
Permit Conditions/Applicable Regulations
Condition A.2 contains the 15A NCAC 2D .0202 permit renewal and emissions inventory requirements. The facility was
issued the most recent permit on March 7, 2018 after submitting a name change from "Alexander Fabrics, LLLP"to
"McComb industries, LLLP." The permit expires on July 31, 2022,and the facility must submit a renewal request and air
pollution emission inventory report for the 2021 calendar at least 90 days prior to the expiration of this permit. This
condition was discussed with Mr. Kauwell. Compliance is expected.
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Condition A.3 contains the 15A NCAC 2D. 0503 "Particulates from Fuel Burning Indirect Heat Exchangers"
requirement. This condition applies to the natural gas-fired textile finishing oven(ES-1),the natural gas/No. 2 fuel oil-
fired hot oil heater(I-ES-10), and the two-natural gas/No. 2 fuel oil-fired boilers(I-ES-30 and I-ES-40). The following
table is borrowed permit review R10 (Taylor Hartsfield, August 8,2014):
_......
Emissions i Construction Individual Heat Input Maximum Heat'Input Allowable Emission Rate
Source ID ( Date Rate [MMBtu/hr] 1 Rate(Q) [MMBtu/hr] (E) [lbs/million Btu]
2009 � ---_9A __... � 50.3 ._....._ .�._ ._i _......� 0.39
I I-ES-10 1-1 985 µ 7.76 � W 7.76 0.60
I-ES-30 F 1988 � F 16.74 F 41.3 1 0.42
..................................................................._._.............. ................................................................................................................................................................................................................_. _.._.....__......................................_........._....�........_..........._..._..._....:......_. ......................_................._........._......................................_................_.
I-ES-40 I 1988 1 16.8 41.3 C 0.42
The emissions rates were calculated and deemed acceptable for combustion of both natural gas(0.0075 lbs/MMBtu)and
No. 2 Fuel Oil(0.024 lbs/MMBtu). These heat exchange units appeared to be operated correctly and according to
manufacturer's recommendations. Compliance is expected.
Condition A.4 contains the 15A NCAC 2D .0515 particulate control requirement. This condition sets the maximum
allowable particulate emissions for the natural gas-fired oven (ES-1)and the hot oil-heated finishing oven (ES-2).
E=4.10 * (P)06' for P<=30 tons/hr, or
E= 55 * (P)0"-40 for P>30 tons/hr
The following table, which is based on CY2013 emissions inventory, is borrowed permit review R10(Taylor Hartsfield,
August 8, 2014):
....... ..... �.. .......... ......................_._ ..__. .
Process Weight Rate Allowable Emissions Actual Emissions Rate,,��
Emissions Source p tons/hr Rate E Ibs PNVhrl Ilbs PM/hr
Natural gas-fired textile finishing oven(ES-1) .___ 0.366 [ 2.09 0.79
Hot oil-heated textile finishing oven(ES-2) 0.366 � 2.09 Did not operate
_......_...._....................._..._...................._..........._..................................................................................._.._......._..........................................................................._.................................._........_._..........................._......._...._....._.._.._......._........_._.......__..._......._.........._.............._........_....................................
*Calculated by taking actual emissions in tons per year times 2000 pounds per ton divided by the number of hours the source operated in CY2013 as
reported in the emissions inventory.
The subject equipment and associated ductwork appeared to be in good condition. Actual emissions are less than the
allowable emissions and compliance is demonstrated.
Condition A.5 contains the requirements for 15A NCAC 2D. 0516, "Sulfur Dioxide Emissions from Combustion
Sources." The rule,which applies to the natural gas-fired textile finishing oven (ES-1),the natural gas/No. 2 fuel oil-fired
hot oil heater(I-ES-10), and the two-natural gas/No. 2 fuel oil-fired boilers(I-ES-30 and I-ES-40), states that the facility
shall not exceed 2.3 lb/MMBtu of sulfur dioxide emissions. The emissions were calculated to be 0.00059 Ib/MMBtu from
the combustion of natural gas and 0.507 lb/MMBtu from the combustion of No. 2 fuel oil. Compliance is expected.
Condition A.6 contains the 15A NCAC 2D .0521 visible emissions control requirement. This facility is limited to 20%
opacity visible emissions, for sources manufactured after July 1, 1971,when averaged over a six-minute period. The
facility and finishing ovens were built in 1981. The opacity observations on the finishing oven, ES-1,and fume eliminator
were between 0-5%. Compliance is expected.
Condition A.7 contains the 15A NCAC 2D .0535 notification requirement for excess emissions during a malfunction or
breakdown that lasts for more than 4 hours. No incidents or malfunctions were reported. There are no issues registered in
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IBEAM for this facility. Mr. Kauwell was not aware of any malfunctions occurring. Compliance with the condition is
expected.
Condition A.8 contains the 15A NCAC 2D .0540 fugitive dust control requirement.No fugitive dust was observed
traveling beyond the property boundaries during this inspection. According to the DAQ IBEAM database,no complaints
have been received regarding fugitive dust emissions at this facility. Compliance with this condition is expected.
Condition A.9 contains the 15A NCAC 2D .1806 control of odorous emissions requirement. No objectionable odors
around the facility boundary were noted during the inspection. There have been no complaints regarding odors at the
facility. Compliance with the condition is expected.
Condition A.10 contains the 15A NCAC 2Q .0315 "Synthetic Minor Facilities"limitation to avoid the applicability of
15A NCAC 2Q .0501. The facility requested this limitation to obtain a synthetic minor classification and avoid being
classified as a Title V facility. The facility must control particulates from the natural-gas fired(ES-1)and hot oil heated
textile finishing oven(ES-2)with the fume eliminators(CD-1, CD-2). The facility should conduct routine maintenance,
inspections,repair as needed, and follow appropriate manufacturer's guidelines. At a minimum,the facility must perform,
annually,an internal inspection on each device and record the results in a logbook. This annual requirement should
include inspections of spray nozzles,packing material, chemical feed system(if applicable),and the cleaning/calibration
of all associated instrumentation. McComb Industries conducted bi-annual inspections and maintenance on the affected
sources. The McComb maintenance records were shared with this inspector via email. The records indicated that the
most recent internal inspection was performed on July 8, 2021. Previously,the maintenance was performed on January 4,
2021 and July 14, 2020. These maintenance inspections include checks of the pumps, flow meters, leaks, filters,fan
motors, and the body of the equipment for leaks or cracks. The most recent internal inspection and maintenance cycle
included bag filter replacements, CVM draining, and a swap out of the nozzles. The facility typically performs these bi-
annual inspections during the July 4 and Christmas holidays. In addition,the facility performs weekly visual checks of
the piping and water flow and other maintenance as needed. These records are kept in an electronic spreadsheet.
Compliance is expected.
Condition A.11 contains the 15A NCAC 2Q. 0711 requirements pursuant to"Emissions Rates Requiring a Permit."The
facility may not exceed any of the Toxic Permit Emission Rates(TPER)as listed in the 2Q .0711 regulations. Prior to
exceeding any TPER,the facility must modify their air quality permit. The triggered toxic air pollutants include,Acetic
acid, Ammonia, Benzene,Chlorine, Formaldehyde, Perchloroethylene(tetrachloroethylene), and toluene. The following
table is borrowed from permit review R10(Taylor Hartsfield,August 8, 2014)and reflects the emissions and the TPER
limits associated with each toxin.
Toxic Air Pollutant(CAS#), TPER , 2013 Actual Emissions*',
.._: ......._...
Acetic acid(64-19-7) 0.96 lb/hr 0.19 lb/hr
[Ammonia(as NH3)(7664-41-7) 0.68 lb/hr 0.038 lb/hr
Benzene(71-43-2) I8.1 lb/yrF 0.1 lb/yr
Chlorine(7782-50-5) { 0.791b/day;0.23 Ib/hr Not reported
__....._......_......._...T....___.....___.................. ._...___.......___.._..:........._..._...... i..____..�.___...._.._._._..._............._..........................-.........._...._..._..._.._.........................
_.........._......_........._...._...._..___._._._..................._........_._.....___._...._......,.._.__.__._......_......_........
Formaldehyde(50-00-0) i 0.04 lb/hr 0.00161b/hr
........................:.................._............................................_.................:.....:.........:_.._....._......................................................_......._............................_.............:., ...__.......,,....:.:.......:.:......:._........._...�.................................._........................:_.........:.:.:.......:......
Perch loroethy len e(tetrachloroethylene)(127-18-4) ! 13,000 lb/yr C 27.5 lb/yr
Toluene(108-88-3) 981b/day; 14.41b/hr 1.63 * 10-31b/day;3.39 * 10-1 lb/hr
I*Calculated using reported emissions in units of pounds per year and converting units based on 2013 actual operation scenario of 20 hours per day,
5 days per week,and 48 weeks per year.
..... ....._......_......................._...._......................._..._........___......._._...__..._.._............_ ......-.........._....___......._............................ m........__................ ...................._._........_......_...__...._._.._..__......_..._._.... __.._...... _m._.........
Compliance is expected
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NSPS/NESHAP
The regulation NESHAP 40 CFR 63 Subpart JJJJJJ(0)for"Industrial, Commercial,and Institutional Boilers at Area
Sources"applies for the exempt two natural-gas/No. 2 fuel oil-fired boilers (I-ES-30 and I-ES-40). However,the facility
is avoiding the applicability by taking the special exemption for liquid fuel backup. The facility must only burn natural
gas except for periods of gas curtailment, gas supply interruptions, startups, or for periodic testing on liquid fuel. The
facility has not used liquid fuels in the boilers and has no intention or expectation of switching from natural gas.
Facility Wide Emissions
Actual emissions, based on 2013 emission inventory information are borrowed from permit review R10(Taylor
Hartsfield,August 8, 2014)
. ..... .... ..
Pollutant Actual Emissions [tons/year] I Potential Emissions [tons/year]
(CY2013) without controls or limits with controls and limits
__.
PM.... i....... 0.97 297.13... 7.44
.............._._......._..__.................
PMto 0.93 294.09 _.._._.............._..........._..........;
PMz.s 0.04 0.39 0.39
_:............:......._.................__...._.. _..:.:.:.:.:...__....._:.............................._........:.:.:.:T:.................................................:...:_...:.. ___...__...........,
SOz 0.01 91.76 91.76
..........................................................................................................................................................................................................._...................................... ........................,-......_.............................__.,......_............................................:..._.._........_.-.._...........
2.39 29.70 j 29.70
CO 2.00 18.15 18.15
VOC 1.31 4.72 4.72
HAPTota1 �_.._...
...
.... 0.32
HAPxigheut(Glycol ethers) 0.20 0.72 0.72
Permit issues
The facility may consider removing the hot oil finishing oven(ES-2)and associated fume eliminator(CD-2)from the
permit during the next renewal if the equipment would not be used again.
Compliance History
This facility has not been issued a NOD,NOV, or NOV/NRE in the past 5 years.
Conclusion
Based on visual observations and review of records, McComb Industries, LLLP appears to be in compliance with all
applicable Air Quality standards and regulations at the time of this inspection.
6