AQ_F_0000016_20210119_CMPL_InspRpt (4)

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NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Glen Raven, Inc.
NC Facility ID 0000016
Inspection Report County/FIPS: Yancey/199
Date: 01/19/2021
Facility Data Permit Data
Glen Raven, Inc. Permit 04104/R12
73 East US Highway 19 East Issued 1/18/2018
Burnsville,NC 28714 Expires 12/31/2025
Lat: 35d 55.0667m Long: 82d 16.7333m Class/Status Small
SIC: 2221 /Weaving Mills, Synthetics Permit Status Active
NAICS. 31321 /Broadwoven Fabric Mills Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Randy Hughes Wendell Wilson Kelsey Herring NSPS: Subpart Dc
Maintenance Manager Plant Manager Engineer
[phone] [phone] [phone]
Compliance Data
Comments: Facility appears to be in compliance.
Inspection Date 01/19/2021
Inspector's Name Lisa Whitaker
Inspector's Signature: ` � Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: February 1,2021 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
*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 Methods) Source(s)Tested
Directions From Asheville take Highway 19/23 to Mars Hill and bear right and continue on Highway 19 to
Burnsville. The facility is located at the intersection of Main Street and Highway 19 on the north end of town on
the left.
Facility Overview
a. Facility Description: Glen Raven Mills operates a filament weaving operation and manufactures cloth for
outdoor furniture, flags, backpacks, sailboat sails, military vest, and other rugged outdoor gear. The facility

currently has approximately 145 employees, operates 3 shifts per day(24 hours a day) 5 days a week,with the
exception of the week of July 4 and Christmas,which they are closed. Occasionally the facility operates on
Saturday when needed.
The facility may be eligible to be exempt from air permitting because the air emissions reported in the most
recent inventory are below the current permitting thresholds. This matter was discussed with facility
personnel in the past. Mr. Hughes declined permit exemption at the time. The facility renewed their air
permit in January 2018. The air permit will expire December 2025.
b. Safety Equipment: Hearing Protection is recommended. Rings not permitted in production area.
Attention to slick floors in heat range room is also recommended.
c. Inspection Summary: On January 19, 202, I (Lisa Whitaker) emailed Mr. Hughes, facility contact, with
targeted Air Quality compliance related questions and a request for I&M records to document compliance.
On January 19, 2021, Kelsey Herring replied with contact update,requested records and question responses as
noted in the pertinent sections below.
In a determination request, DAQ received notification that Glen Raven planned to run trials of adding finishes
to the fabric processed by the existing Heat Set Range (HS-1). DAQ determined that no permit modification
is required under those described circumstances. When asked for a status update, Ms. Herring reported, The
trials are coming along very well, we are pleased with the efficiency and minimal requirements of the new
coating equipment. There had been some delay in the trial work due to this being new equipment that our
associates had to learn on top of the ups and downs of COVID. The goal is to wrap up the trial work and
submit all final documentation later this winter. Ms. Herring also stated,As mentioned, there is new coating
equipment that has been added to the small finishing range (HS-1). This is in the distribution building "on top
of the hill"or to the left when pulling into visitor parking. There were no emission points added nor any
structural changes to existing stacks. The equipment has a relatively small footprint and was simply added to
the range line. There have been no other changes to the facility equipment.
On January 29, I traveled to the facility address to conduct a direct, off-site visible emissions evaluation of
release points. I observed release point of boiler 2 (B-2) in operation and documented 0%VE at the time.
Emission Source and Regulatory Review
Source Listing
Emission �� Emission Source Control !Control System
Source ID Description j System ID Descri on
B-1 and B-2 two propane/natural gas-fired boilers
N/A N/A
I NSPS (12.5 million Btu per hour maximum heat input rate, each)
HS-1 one natural gas/propane-fired heat set range
,(comprised of two zones,each with 1.5 million Btu per hour maximum N/A N/A
;heat input rate)
� —EL-1 extrusion lines I
N/A N/A
._. .. ..._........ ................
A. SPECIFIC CONDITIONS AND LIMITATIONS

1.The Permittee shall comply with applicable Environmental Management Commission Regulations, including Title 15A
North Carolina Administrative Code(NCAC), Subchapter 2D .0202,2D .0503,2D .0515,2D .0516,2D .0521,2D .0524
(40 CFR 60, Subpart Dc),2D.0535,2D .0540,2D .1806 and 2Q .0711.
Conditions are evaluated individually and addressed separately below. Facility appeared to be in compliance.
2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT—Permits do not automatically renew.
Permittee is required to submit permit renewal application,including an emission inventory for the 2024 production year,
as detailed in the renewal reminder letter,when it is issued.
This condition was not addressed. The facility will be inspected several more times before the renewal is required.The
most recent renewal, and accompanying inventory,were received and approved for R12. Facility appeared to be in
compliance.
3. PARTICULATE CONTROL REQUIREMENT-As required by 15A NCAC 2D .0503 "Particulates from Fuel Burning
Indirect Heat Exchangers," which applies to boilers(ID Nos. B-1 and B-2). Particulate emissions of subject sources are
limited to 0.47 lbs/million Btu.
This condition was addressed as part of the inventory received and approved for renewal of R12. Facility appeared to be in
compliance.
4. PARTICULATE CONTROL REQUIREMENT-As required by 15A NCAC 2D .0515 "Particulates from Miscellaneous
Industrial Processes,"which applies to the extrusion lines(ID No.EL-1)and heat set range(ID No.HS-1. Particulate
emissions of subject sources are limited by equations detailed in the permit.
This condition was addressed as part of the inventory received and approved for renewal of R12. Facility appeared to be in
compliance.
5. SULFUR DIOXIDE CONTROL REQUIREMENT-As required by 15A NCAC 2D .0516 "Sulfur Dioxide Emissions
from Combustion Sources,"which applies to boilers(ID Nos. B-I and B-2)and the heat set range(ID No. HS-1). Sulfur
dioxide emissions of the subject sources shall not exceed 2.3 pounds per million Btu heat input.
This condition was addressed as part of the inventory received and approved for renewal of R12. Facility appeared to be in
compliance.
6. VISIBLE EMISSIONS CONTROL REQUIREMENT-As required by 15A NCAC 2D .0521 "Control of Visible
Emissions," which applies to sources manufactured after July 1, 1971. Sources permitted in R12 except ID Nos.B-1 and
B-2 shall operate under visible emission limit of 20%opacity when measured as detailed in the permit.B-1 and B-2 are
subject to condition A.7.
To evaluate this condition,I traveled to Glen Raven,Inc.to make a direct observation of release points. At that time, I
observed release point of B-2 in operation and observed 0%VE during that site visit. Facility appeared to be in
compliance.
7. 15A NCAC 2D.0524 "NEW SOURCE PERFORMANCE STANDARDS" as promulgated in 40 CFR 60, Subpart Dc,
including Subpart A"General Provisions.". This condition applies to propane/natural gas-fired boilers(ID Nos. B-I and
B-2), and requires,the Permittee is required to maintain records of the amounts of each fuel combusted during each
month;records to be maintained for a period of two years following the date of such record.
To evaluate this condition, I requested and reviewed fuel records. Ms. Herring provided pdf versions of fuel records which
document monthly usage between 2000-4300 dth Natural Gas combustion and zero gallons of LP.Facility appeared to be
in compliance.
8.NOTIFICATION REQUIREMENT-As required by 15A NCAC 2D .0535,the Permittee of a source of excess emissions
that last for more than four hours and that results from a malfunction,a breakdown of process or control equipment or any
other abnormal conditions shall notify DAQ as detailed in the permit.
Ms. Herring stated, the facility has not had any operation upsets. Facility appeared to be in compliance.
9. FUGITIVE DUST CONTROL REQUIREMENT-As required by 15A NCAC 2D .0540 "Particulates from Fugitive Dust
Emission Sources,". The facility is required to operate in a manner that does not cause or contribute to substantive
complaints or excess visible emissions beyond the property boundary.
Ms. Herring stated, the facility has not received any complaints regarding the facility's operations.No complaints have
been received by ARO. Facility appeared to be in compliance.

10. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS-As required by 15A NCAC 2D .1806"Control and
Prohibition of Odorous Emissions" Permittee shall not operate the facility without implementing management practices
or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing
or contributing to objectionable odors beyond the facility's boundary.
Ms. Herring stated,the facility has not received any complaints regarding the facility's operations.No complaints have
been received by ARO. Facility appeared to be in compliance.
11. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT-Pursuant to 15A NCAC 2Q .0711
"Emission Rates Requiring a Permit,". Facility must operate to limit vinyl chloride(75-01-4)to 26 lb/hr.
This condition was addressed as part of the inventory received and approved for permit renewal and issuance of R12.
Facility appeared to be in compliance.
B. GENERAL CONDITIONS AND LIMITATIONS
16. CLEAN AIR ACT SECTION 112(r)REQUIREMENTS-Pursuant to 15A NCAC 2D .2100 "Risk Management
Program," if the Permittee is required to develop and register a risk management plan pursuant to Section 112(r)of the
Federal Clean Air Act,then the Permittee is required to register this plan with the USEPA in accordance with 40 CFR
Part 68.
RMP Not Required—Glen Raven 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.
INSIGNIFICANT SOURCES:
Source Exemption Source of Source of Title
Regulation TAPS? V Pollutants?
I-1 -one slashing process consisting of five slashers and two
2Q.0102
natural gas-fired dryers Yes Yes
(h)(1)(B)
(3.5 million Btu/hr maximum heat input rate,each)
No sources from this list were observed. There are no known DAQ regulations that govern the operations or
maintenance of the slasher/dryer process.
SOURCE TEST REVIEW: A review of the Source Test Ibeam module documented that no source tests have been
conducted. No source tests are pending.None appear to be required.
COMPLIANCE HISTORY REVIEW: A review of the Violations history for Glen Raven documented that no Notices of
Violation or Notices of Deficiency have been issued in the last five years. Glen Raven was issued an NOV for late report
submission in 2008.
EMISSION INVENTORY REVIEW: A review of the ED Ibeam module documented that the most recent inventory was
reviewed and approved by Bob Graves,of this office, in 2012. Mr.Graves observed that emission changes from previous
inventory due to type and amount of fuel changes.
FINAL COMPLIANCE DETERMINATION/RECOMMENDATION: Based on the evidence reviewed to evaluate
compliance with Glen Raven's permit,the facility is found to be in compliance.