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HomeMy WebLinkAboutAQ_F_0000016_20190205_CMPL_InspRpt (4) NORTH CAROLINA DIVISION OF Asheville Regional Office AIR QUALITY Glen Raven,Inc. NC Facility ID 0000016 Inspection Report County/FIPS: Yancey/199 Date: 02/05/2019 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 Randy Hughes NSPS: Subpart Dc Maintenance Manager Plant Manager Maintenance Manager (828)682-2142 (828)682-2142 (828)682-2142 Compliance Data Comments: Inspection Date 02/05/2019 Inspector's Name Angela Hopper Inspector's Signature: it-"_-�1 ;a Operating Status Operating Compliance Code Compliance- inspection e, Action Code FCE Date of Signature: / On-Site Inspection Result Compliance - 1� tl� -1 Total Actual emissions in TONS/YEAR: TSP SO2 NOX VOC CO PM10 *HAP 2016 0.0800 1.18 0.0500 0.9600 0.0800 39.91 2012 0.0900 --- 1.14 0.0600 0.9500 0.0900 41.00 * 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 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. Safety Equipment: Hearing Protection. Note:No rings can be wom. Safety issues: Floors in heat range room may be slick,especially if wet. b. Discussion: On February 5, 2019,I traveled to the facility to conduct an unannounced routine annual compliance inspection. I arrived at the facility at approximately 10 am and was on site for around 1 hour. I met and toured the facility with Mr.Jeremiah Autrey, Lead Electrician and the back-up for Mr. Randy Hughes, Maintenance Manager and Facility Contact. Mr. Hughes joined us for parts of the inspection. The facility maintains a copy of their current air permit on site. The facility was lasted inspected by me on November 28,2017. c. Facility Contacts:No changes or updates to the facility contacts. Because there is no reception staff,you will need to call Mr. Hughes on his cell phone at(828-284-2636) from the facility parking lot. Mr. Autrey's cell phone number is(828-682-2142). d. Facility Description: Glen Raven Mills operates a filament weaving operation and manufactures cloth for outdoor furniture,flags,backpacks, sail boat 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. Permit Exemption Eligibility: The facility may be eligible to be exempt from air permitting because their current air emissions are below the current permitting threshold. This matter has been discussed with facility personnel in the past. I discussed the possibility of exemption with Mr. Hughes and Mr. Autrey during this site visit. Mr. Hughes said that he would pass the information along to the company's corporate Environmental and Sustainability Engineer,Kelsey Herring. The facility renewed their air permit in January 2018. The air permit will expire December 2025. Emission Source and Regulatory Review: Source Listing: Emission Emission Source Control Control Source ID Description System ID Sstem [Desycription B-1 and B-2 two propane/natural gas-fired boilers NSPS (12.5 million Btu per hour maximum heat N/A N/A input rate, each)Manufacturer date: 1998 for both. HS-1 One natural gas/propane-fired heat set range (comprised of two zones, each with 1.5 million N/A N/A Btu per hour maximum heat input rate) EL-1 JExtrusion Lines N/A N/A Boiler ES ID B-2 was observed in operation using natural gas at 100 psi with no visible emissions during this inspection. Boiler ES ID B-1 was operating on low fire mode or stand-by mode. Propane is fired i it i I' once a month for testing and during times of natural gas curtailment. It may be noted here that natural gas and propane fired boilers are not subject to the boiler GACT,NESHAPs, Subpart JJJJJJ. HS-1 was observed in not in operation. The natural gas/propane fire heat set range(comprised of two zones, each with 1.5 million Btu per hour maximum heat input rate). This equipment is currently being operated 2 days a week on Monday and Thursdays. The equipment was previously operated at the company's Anderson, SC facility. It was moved to the Burnsville site and began operating in October 2017. According to facility personnel,the natural gas/propane heat set range works the same as a tenter frame and is used for heat setting PVC coating for outdoor furniture. Generally,the heat set range runs 20 yards of material a minute. There is a two-burner oven operated by natural gas associated with the range. ES-I was observed in operation with no visible emissions. There is a total of 5 extrusion lines which were installed in April of 2017 and are operated 5 days per week but usually not all at one time. Lines 2, 4 and 5 were observed in operation during my site visit. The extrusion lines are located in the basement of the facility. The exhaust for the extrusion lines is handles by a large building wall exhaust fan. Permit Conditions: 2D .0503 -Particulates from Fuel Burning Indirect Heat Exchangers-Particulate matter emissions from the boilers show compliance based on the on the AP-42 emission factors(see files). r 2D .0516 - Sulfur Dioxide Emissions from Combustion Sources -This regulation limits SO2 emissions from combustion sources to 2.3 lbs/mmBtu. According to the analysis in the March 21, 2001 memorandum by Laura Herbert, Permits Coordinator, combustion of propane is expected to comply with 2D .0516. It may be noted that because all SO2 emission sources at this facility are subject to 2D .0524, therefore,Rule 2D .0516 does not apply. Additionally,the facility no longer fires their boilers on fuel oil. The boilers now fire only natural gas and propane(see files). Compliance is indicated 2D .0521, Control of Visible Emissions: Boilers B-1 and B-2 were manufactured in1998 and thus have a 20% opacity limit. The facility is no longer using No. 2 fuel oil;the facility is only using natural gas with propane as a backup fuel. During this inspection,no visible emissions were observed. Compliance is indicated. 2D .0524 -New Source Performance Standards-40 CFR 60, Subpart Dc: The effective date for NSPS, Subpart Dc, is June 9, 1989. Both boilers(ID Nos. B-1 and B-2)were manufactured in 1998, and are therefore subject to NSPS, Subpart Dc.These boilers are fired only with natural gas or propane. Record keeping is now monthly(ref. 40 CFR 60.48c(g)(2)). Also; because this facility is not required to demonstrate compliance with the fuel oil sulfur limit listed in 40 CFR 60.48c(e)(11). Additionally,the facility is no longer required to maintain fuel supplier certifications. Note: All SO2 emission sources at this facility are subject to 2D .0524,Rule therefore, 2D .0516 does not apply. The facility is tracking their fuel combusted. Compliance is indicated. NSPS Recordkeeping Requirements-In addition to any other recordkeeping requirements of the EPA, the Permittee is required to maintain records as follows: 4 i. The amounts of each fuel combusted during each month; and ii. All records required under this section shall be maintained for a period of two years following the date of such record. Ii During the inspection, I unable to review the fuel records. Mr. Hughes was having computer issues at the time of my site visit and was unable to download the fuel records. He e-mailed the 2018 natural gas records on February 8, 2019. Compliance is indicated. b. NSPS Emissions Limitations -As required by 15A NCAC 2D .0524,the following permit limits shall not be exceeded: Affected Source(s) Pollutant Emission Limit two boilers sulfur content 0.50 pounds per million (ID Nos. B-1 and B-2) i Btu of heat input 2D .0540 -Particulates from Fugitive Non-Process Dust Emission Sources-There have been no substantiated complaints related to compliance with 2D .0540 during the past five years. No fugitive dust issues were observed during this inspection. Compliance is indicated. 2D .1806 -Control of Prohibition of Odorous Emissions-There have been no odor complaints with regards to this facility over the past five years. During the inspection, no objectionable odors were observed. Compliance is indicated. Record Keeping and Reporting Requirements Review: The facility has a NSPS reporting requirement. Because the facility no longer burns fuel oil,they only need to log fuel(natural gas/propane) usage monthly and reporting is no longer required(see 2D. 0524 above). Mr. Hughes was having computer issues at the time of my site visit and was unable to download the fuel records. He e-mailed the 2018 natural gas records on February 8, 2019. Compliance is indicated. Insignificant Sources Listing: The Permittee operates a slashing operation(ID No. I-1)that consists of five slashers and two propane/natural gas-fired dryers (3.5 million Btu/hr heat input rate, each). This operation is exempt from permitting per 2Q .0102(c)(2)(E)(i). During the inspection,I observed the slashers in operation with no VE's: The facility's five-year compliance history is as follows: There have been no documented violations in the last five years. Stack Test Review: No stack tests have been conducted during the last 5 years. There are no stack test requirements in the facility's current air permit. 112r Review: The facility is not subject to the requirements of 112(r). Compliance Assistance: None needed at this time. Recommendation: None. Compliance Statement: During this inspection,this facility appeared to be in compliance with Air Permit 04104R12.