AQ_F_0100301_20190718_CMPL_CAV-Rpt (4)

NORTH CAROLINA DIVISION OF AIR QUALITY Winston-Salem Regional Office
C intas Graham
Inspection Report NC Facility ID 0100301
Date: 07/22/2019 Coun /FIPS: Alamance/001
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
[phone] [phone] Engineer
[phone]
Compliance Data
Comments:
Inspection Date: 07/18/2019
Inspector's Name: Thomas Gray
Inspector's Signature: Operating Status: Operating
•y
Compliance Code: Compliance- inspection
Action Code: FCE
Date of Signature: ', , ' MTH On-Site Inspection Result: Compliance
Total Actual emissions in TONS/YEAR:
TSP SO2 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:
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Emissions .s
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Emissions Sources Control Devices
Industrial Laundering Operation (13,500 tons of soiled shop textiles per year capacity)
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Natural gas-fired industrial drying equipment N/A
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Industrial washing equipment N/A
Industrial wastewater treatment plant N/A
Natural gas-fired support equipment N/A

Introduction:
On July 18,2019, Mr.Thomas Gray, Environmental Specialist 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). This facility was last inspected on August 16,2018,by Mr. George Williams, Environmental
Engineer I, also of the WSRO-DAQ, 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 PM 10, 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. 10141 R04 was officially
rescinded,and Registration No. 0 10030 1 X00 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 CAV.
Safety:
The required PPE at the facility consists of the following: safety shoes, safety glasses,ear plugs. Inspectors should be aware of the 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:
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 CAV began with Mr. Whitley taking Mr. Gray on a walk-through of the facility. All eight
industrial washers(six large and two small)were observed during the CAV. Six of the eight washers(large washers)were observed
operating with no visible emissions, indicating likely compliance with 2D .0521. Next,the facility's five natural gas-fired industrial
driers were observed operating with no visible emissions indicating likely compliance with 2D .0521. Finally,the facility's natural
gas-fired boiler and industrial wastewater treatment plant were observed. The boiler was operating with a steam pressure of 90 PSI,
and a stack temperature of 390 degrees Fahrenheit, with no visible emissions, indicating likely compliance with 2D .0521. The boiler
is used to heat the water used in the industrial driers.
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.
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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.I o(P)0.67
If P>3 0 tons/hr:E=5 5.0(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 based 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
Y YP ton/hr lbs/hr lbs/hr
Type 1 660 lb load 0.66 3.1 1.70
Type l 700 lb load 0.7 3.23 1.81
Pony type 125 lb load 0.125 1.02 0.32
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/MMBtu 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. During the
inspection, no visible emissions were observed, 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 inspection,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. During the CAV,no fugitive dust was observed, and no
complaints have been recorded in the DAQ IBEAM database since the previous inspection. 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. During the CAV, a slight odor was noted around the facility's industrial
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wastewater treatment operation. The odor was confined to the operation and was not apparent beyond the facility boundaries.
Compliance with 2D .1806 is indicated.
Facility-Wide Emissions:
Pollutant Actual Emissions(CY2018) Potential Emissions
[tons/yr] [tons/yr]
PM
....... ..... . ............ ....... 1.20 12.19
I PMia
________ �SO2 �N 0.00 0.07
__............._....._........__........._...._..._......._........... ............_. _.....__...-......_�....._......._........�..........._...
NO,� 0.67 11.44
VOC 2.20 ( 92.09
�_._.�...._.m._...__HAPTora�
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 Testinp_:
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.
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