AQ_F_0300073_20190711_CMPL_CAV-Rpt (4)

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY Parkdale Mills,Inc.-Plants 36&37
NC Facility ID 0300073
Inspection Report County/FIPS: Alleghany/005
Date: 07/12/2019
Facility Data Permit Data
Parkdale Mills, Inc. - Plants 36&37 Permit n/a
164 Pine Swamp Road Issued n/a
Sparta,NC 28675 Expires n/a
Lat: 36d 28.9200m Long: 81 d 5.9760m Class/Status Registered
SIC: 2281 /Yarn Mills, Except Wool Permit Status Inactive
NAICS: 3131 1 1 /Yarn Spinning Mills Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Bill Buchanan Randy Doyle Rob Adams
Plant Manager Facilities Engineer Engineer
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 07/11/2019
Inspector's Name Shannon Leonard
Inspector's Signature: Operating Status Operating
Compliance Code Compliance- inspection
Action Code FCE
Date of Signature: -7 l la`t�t MTH On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2010 16.72 --- --- --- --- 7.11 ---
2005 18.80 --- --- --- --- 8.00 ---
* Highest HAP Emitted in poun s
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
EMISSION EQUIPMENT TABLE
Emissions Sources Control Devices
Yarn spinning operations and associated air filtration system(s) N/A
_.... ...... ................._.. ..... ... .._.. . ........ _....... _. ................... ._......... .... .
Fuel storage operations N/AV i
.................. ...... .. ... .... ........................ . ... ...... . ..... ............ ............ ........... ..
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INTRODUCTION
On July 11,2019, Shannon Leonard,DAQ-WSRO Environmental Engineer,contacted Mr. Bill Buchanan, Plant Manager, in order to
conduct an announced,targeted compliance assurance visit at the above referenced facility. Mr. James Edwards, HVAC Technician,
also assisted with the inspection.The facility has a Registered classification. Mr.Buchanan indicated the authorized contact data needs
to be changed,and IBEAM was updated accordingly.The facility was previously inspected by Mr. Paul Williams, former DAQ-
Environmental Specialist,on November 8,2016.At that time,the facility appeared to be operating in compliance with Air Quality
rules and regulations.Parkdale Mills,Inc-Plants 36&37 manufactures yarn from raw cotton and synthetic materials.The facility
operates 24 hours/day,7 days/week,and 52 weeks/year.
SAFETY
Required safety equipment for this site includes safety shoes, safety vest,and hearing protection.A hard had is required to access roof.
LATITUDE/LONGITUDE VERIFICATION
The latitude and longitude coordinates of the facility were verified.
APPLICABLE REGULATIONS
Parkdale Mills, Inc-Plants 36&37 are subject to the following regulations:Title 15A North Carolina Administrative Code (NCAC),
Subchapter 2D.0202,2D.0515,2D.0521,2D .0535,and 2D.0540.
DISCUSSION
Parkdale Mills,Inc-Plants 36&37 are yarn spinning mills that produces cotton yard stock for various companies.The two largest
customers are Fruit of the Loom and Hanes Brands.Both plants produce"ring spinning"yarn from raw cotton and/or polyester
materials. Ring spinning yarn is a higher quality yarn and requires more processing verses open-end spinning.The facilities produce
100%cotton yarn and 60/40 cotton&polyester blend yarn. The process begins as bales of cotton and/or polyester materials are
received. Each bale of cotton has been tested for fiber qualities at the cotton gin processing facility. Due to the inconsistent fiber
qualities of cotton,the cotton bales are numbered and assorted to be placed in a specific order on the processing line to obtain a
desired overall fiber consistency. The fibers of polyester materials are consistent;therefore, bales of polyester materials do not have to
be placed in a specific order on the processing lines.The bales of materials are moved to the opening room, where they are placed
under the top feeder machines.The top feeder machines remove the cotton and/or polyester materials in small increments from the
bales.The fibers are then sent to multi-mixers,which blends all the different fiber materials.Next,the fibers are sent to the CLC4
machines,which cleans and opens the fibers.Then the fibers are sent to the dust-tex machines,which removes dust from the fibers.
Next,the fibers are sent to the card machines.The card machines remove any remaining trash from the fibers,aligns the fibers, and
removes smaller fibers of undesired lengths.During this process,the card machine takes several thin strands of fibers and twists them
together into a single cord(—I"in diameter),called sliver.The sliver is then coiled and placed into large baskets.The sliver then goes
through two processes of drawing machines,which continues to align the fibers.The sliver is sent through the roving machines, which
continues to align the fibers and reduces the sliver down to a smaller size(—'/8"in diameter),called roving.The roving is sent to the
spinning frames,which continue to align and draft the fibers,and then twist the fibers into yarn. The yarn is spun onto spinning
bobbing's,which are sent to a winding process to make the larger yarn packages for shipping. Loose fibers and dust are removed from
the air through intakes, which are located along the spinning machines, including floor ducts which collect loose fibers.This
particulate waste is ducted to large drum filters and fine dust filters for removal before being transferred to air-wash stations. There is
a total of 6 air filter rooms, 3 for each plant. During the inspection,only one filter room was entered since all rooms are similar in
processing/cleaning the air.The filtered and conditioned air is exhausted back into the building during the summer months and
exhausted to the atmosphere during the winter/cooler months. Mr. Edwards indicated all the filters are inspected every Monday and
are cleaned/replaced as necessary. Collected fibers are sent to an area to be re-processed and baled.These fibers are re-introduced
through the process again.The waste fibers and debris are sent to a baling machine for disposal. Discarded waste is sent to companies
for use in other products. The facility has a total of four exhaust stacks, which are located on the northern corner of the Plant 36 roof.
The two smaller stacks(-8")are exhausting hot air directly from some equipment.This air is filtered prior to being exhausted.
Plant 36 is located in the southern portion of the building(it faces Pine Swamp Rd.). It contains two lines consisting of 24 card
machines,20 draw frames, 13 comber machines,6 roving frames,30 spinning frames with 1,104 positions per frame. Plant 37 is
located in the northern portion of the building. It contains two lines consisting of 18 card machines, 15 draw frames, 8 roving frames,
24 spinning frames with 1,200 positions per frame.A center portion of the building serves as packaging and warehouse for both
plants.
During the inspection,both plants were operating,and many of the machines listed above were observed in operation.There were no
visible emissions observed from the four exhaust stacks. The filtered and conditioned air was being exhausted into the building.
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It should be noted that 15A NCAC 2D .1806 appears to have been accidently left out of the Registration. Mr.Leonard did not detect
any odors during the inspection. The facility does not have any previous odor complaints in IBEAM database. The facility appears to
be in compliance with this requirement.
The facility has fuel storage operations in the emissions equipment. This consists of a 1,000-gallon propane tank,which is used to fuel
forklifts. The 250-gallon#2 fuel oil storage tank has been removed from the facility.
Regulations Applicable to this Facility
15A NCAC 2D.0202 registration of air pollution sources.This requirement states that the facility-wide actual total aggregate
emissions of PM 10, sulfur dioxide,nitrogen oxides,VOC's, carbon monoxide,HAP's,and TAP's 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).
These requirements were discussed with Mr. Buchanan and compliance is anticipated.
The facility is also required to maintain records onsite to establish that facility-wide annual emissions remain below the 25 ton per
year threshold. Mr. Buchanan maintains electronic records of total pounds of cotton processed per month for this facility. For
CY2017, Plant 36 processed 18,106 bales of cotton,which equates to 8,952,827 pounds and Plant 37 processed 35,937 bales of cotton,
which equates to 17,758,216 pounds. Total combined from both plants for CY2017 was 26,711,043 pounds.For CY2018,Plant 36
processed 19,403 bales of cotton, which equates to 9,648,273 pounds and Plant 37 processed 21,734 bales of cotton,which equates to
10,806,191 pounds. Total combined from both plants for CY2018 was 20,454,464 pounds.Using a conversion factor of 0.000393 lbs
PM/lb cotton,taken from registration review X00,this production level equates to 5.25 tons of PMIo emissions for 2017 and 4.02 tons
of PMio emissions for 2018.The facility appears to be in compliance with 2D.0202.
15A NCAC 2D.0515 particulates from miscellaneous industrial processes requirement.This rule applies to the air filtration systems
and states that the allowable particulate emissions rates to be:
E=4.10(P)0.6' for P 5 30 ton/hr
E=55.0(P)o-1' -40 for P> 30 ton/hr
where P=process rate(ton/hr)
E=maximum allowable emission rate(lb/hr)
The facility is required to maintain records to show that PM emissions are below the allowable rates and registration thresholds. The
facility maintains records of total pounds of cotton processed per month. The facility appears to be in compliance with 2D .0515.
15A NCAC 2D.0521 visible emissions control requirement.This facility is limited to 20%opacity for sources manufactured after
July 1, 1971,when averaged over a six-minute period.No visible emissions were observed during this inspection.The facility appears
to be in compliance with this requirement.
15A NCAC 21).0535 requires the facility to notify DAQ of any malfunctions associated with a source causing an excess of emissions
lasting more than four hours. Mr. Buchanan indicated there have not been any such incidents. The facility appears to be in compliance
with this requirement.
15A NCAC 21).0540 fugitive dust control requirement. Mr. Leonard did not observe any fugitive dust during the inspection.No
complaints were observed in the IBEAM database.The facility appears to be in compliance with this requirement.
NSPS/NESHAP/112(r)APPLICABILITY
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The facility does not appear to be subject to any NSPS/NESHAP requirements at this time.
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The facility does not use,store,or manufacture any of the regulated substances in quantities above the thresholds for the Section
112(r)program involving Risk Management Practice(RMP)requirements.They are only subject to the General Duty requirements
contained in the General Condition.
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FACILITY EMISSIONS
The following table summarizes the facility wide actual emissions from CY2018.Plant 36 processed 19,403 bales of cotton, which
equates to 9,648,273 pounds and Plant 37 processed 21,734 bales of cotton,which equates to 10,806,191 pounds. Total combined
from both plants for CY2018 was 20,454,464 pounds. Using a conversion factor of 0.000917 lbs PM/lb cotton and 0.000393 lbs
PMio/lb cotton,taken from permit renewal review by Ms. Sharon Wyatt on March 27,2012,the emissions below were calculated.
_., c
Actual Emissiaris nsJye(fo r) .
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PM _ 9.38
SOZ �. ...._ Not reported
NOx � _.._.Y..Y._�_ __._.._�..�._.._._..__.v,.Notreported_..__.w..
�._....._..._ CO .._,_...____....._._�._M Not reported
VOC Not reported
HAPTota1 Not reported
HAPxigheW Not reported
FACILITY CONSIDERATIONS/ISSUES
It should be noted that 15A NCAC 2D .1806 appears to have been accidently left out of the Registration.
COMPLIANCE HISTORY
The facility has not received any Notices of Violation or Deficiency in the last five years.
CONCLUSION
Based on a review of records and visual observations, Parkdale Mills, Inc-Plants 36&37 appeared to be operating in compliance
with Air Quality rules and regulations at the time of this inspection.
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