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Home My WebLink AboutAQ_F_0100301_20200414_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: 04/15/2020 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:PCE due to COVID-19. Inspection Date: 4/14/2020 Inspector's Name: Thomas Gray Inspector's Signature: j � Operating Status: Operating Compliance Code Compliance-inspection j Action Code PCE Date of Signature: / ��/ MTH On-Site 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 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 Methods) Source(s)Tested Emissions Equipment Table: Emissions Sources Control Devices Industrial Laundering Operation(13,500 tons of soiled shop textiles per year capacity) � equipment�Natural gas-fired industrial drying q p � N/A Industrial wash ing equipment N/A �._ g--_ _. . ... ...... .......... ....... Industrial wastewater treatment plant N/A Natural gas-fired support equipment N/A 1 Introduction• On April 14,2020,Mr.Thomas Gray,Environmental Specialist I,of the Winston Salem Regional Office-Division of Air Quality (WSRO-DAQ),contacted via telephone Mr. Steve Whitley,Plant Manager of Cintas Graham,for the purpose of conducting a partial compliance evaluation(PCE).This facility was last inspected on July 18,2019 by Mr.Gray and was found to be operating in compliance with all applicable air quality standards 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,SO2,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. 10141R04 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 PCE.Mr. Whitley stated due to the current COVID-19 restrictions,he was forced to.lay off approximately 50%of the employees as business has slowed considerably. Safety The required uired PPE at the facility consists of the following:safe shoes safe lasses ear plugs.Inspectors should be aware of the low q tY g safety �safety glasses, p g p hanging hooks in the facility. Applicable Re ulations: 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: As mentioned in the introduction,the facility launders linens,towels,and uniforms for multiple private companies on an industrial scale.Products arrive via trucks.The PCE began with Mr.Whitley describing the current facility operations.As mentioned in the introduction,approximately 50%of the employees are currently unemployed as the COVID-19 outbreak has reduced business substantially.Mr.Whitley stated the facility is still operating eight industrial washers(six large and two small),five natural gas-fired industrial driers,and a natural gas-fired boiler.Mr.Whitley stated all have been in operation with no visible emissions other than steam.Mr.Whitley stated the boiler is tuned up semi-annually and is only capable of firing natural gas.Mr.Whitley also confirmed that the facility is no longer accepting print towels and that print towels are sent to a third-party vendor.Mr.Whitley was aware that if the facility began accepting and processing print towels again,the emissions would be that over the registration threshold and the facility would be required to obtain an air quality permit from the DAQ. 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 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. 2 2D.0515—Particulates from Miscellaneous Industrial Processes The facility is applicable to this rule.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.IO(P)0.67 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) This rule is subject to the facility's natural gas-fired drying equipment.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 10-4 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 summarizes the maximum textile rate,as well as the allowable and actual PM emissions for each different dryer type.Compliance is demonstrated. Dryer type Maximum textile rate Allowable PM emissions Actual PM emissions ton/hr lbs/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 a 125 lb load 0.125 1.02 0.32 7771 According to calculations provided 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. S02/1\4MBtu threshold.Continued compliance with 2D .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.Mr.Whitley stated during the call that he hasn't noticed any visible emissions from the emission sources other than steam,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 prior to the call since the last FCE,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. 3 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.Mr.Whitley stated he has noted no odors beyond the facility boundaries. Compliance with 2D.1806 is likely. Facility-Wide Emissions: s Actual Emissions(C�'"20f8) _ Pot�nti�l imissions = I�ollutant ,[tanslyr] [tons/yrj t PM 1.20 12.19 PM10 ......._.D _._,.. m___._ m__._. __._.._. _....__._ _.m___.. mm m _ ..._ SO2:X :. _..Mm. 0.00 0.07 11. . _ NO 0.6744 CO 0.56 9.61 VOC_.. m... 2.20 mm. .. .:.... ..m. 92.09 ... ....... ...... ......... HAPTotal 0.39 16.69 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 PCE. 4