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HomeMy WebLinkAboutAQ_F_0400016_20180829_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Wade Manufacturing Co-Wadesboro NC Facility ID 0400016 Inspection Report County/FIPS:Anson/007 Date: 09/10/2018 Facility Data Permit Data Wade Manufacturing Co-Wadesboro Permit 03577/RI Highway 74 East Issued 9/11/2015 Wadesboro,NC 28170 Expires 1/31/2019 Lat: 34d 57.8720m Long: 80d 2.6476m Classification Synthetic Minor SIC: 2261 /Finishing Plants,Cotton Permit Status Active NAICS: 313311 /Broadwoven Fabric Finishing Mills Current Permit Application(s)Renewal Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Sherry Wallace Bernard Hodges Sherry Wallace Cost Manager President Cost Manager (704)694-2131 (704)694-2131 (704)694-2131 Compliance Data Comments: Inspection Date 08/29/2018 / Inspector's Name Jeffrey D. Cole Inspector's Signature: / Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: cj�/CG//b On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2014 12.39 1.02 5.51 9.77 4.49 12.38 1525.84 2013 11.80 0.0300 5.23 12.30 4.46 11.80 1945.30 *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 downtown Fayetteville,take Raeford Road, Hwy 401, south to Wagram,—32 miles. Just west of Wagram,turn right onto Old Wire Road(SR 144)to Laurel Hill.Turn right on Highway 74,bypass Rockingham,to Wadesboro,—35 miles. Wade Mfg. is on the north(right)side of the Hwy 74,just after the `Welcome to Wadesboro' sign. SAFETY: Standard DAQ FRO Safety Gear. Main safety concerns are slips trips and falls from uneven and slippery floors, stairs, and forklift traffic. FACILITY DESCRIPTION/PROCESS DESCRIPTION: Wade Manufacturing is a Synthetic Minor facility for SO2,mainly from the burning of No. 6 fuel oil. Wade Manufacturing makes,dyes and prints cotton and polyester/cotton blend fabric. The process includes bleaching,dying, printing,and finishing of cloth. This facility has fabric-finishing equipment consisting of natural gas-fired tenter frame ovens and several napping areas. A tenter frame stretches fabric under tension and consists of chains fitted with pins or clips to hold the selvages of the fabric,and travelling on tracks.As the fabric passes through the heated chamber, creases and wrinkles are removed, the weave is straightened,and the fabric is dried to its final size. The napping process is used to raise a velvety, soft surface to fabric. The process involves passing the fabric over revolving cylinders covered with fine wires that lift the short, loose fibers,usually from the weft yarns,to the surface,forming a nap. The process,which increases warmth, is frequently applied to woolens and worsteds and also to blankets. Two natural gas/No. 6 fuel oil-fired boilers are used to provide steam for some of these processes.The company started business in 1926. Wade Manufacturing currently operates under air permit no. 03577R18,which has an expiration date of 31 January 2019. Employees: 117 Hours: 4 or 5 days a week, 7 AM to 3 PM Through-put: Year Throughput in Average weight of Average weight range of million yards fabric(yd/lb) fabric(yd/lb) 2017 F__ 5.17 1.58 0.89 -3.4 2016 599 1.65 0.89 -3.4 2015 6.28 1.49 F 0.89 -3.4 2014 6.77 1.51 0.89 -3.4 2013 � 6.25 1.55 0.89 -3.4 PERMITTED EMISSION SOURCES (PLUS CONTROLS): Emission Emission Source Control Control System Source ED Description System ID Description Natural gas/No. 6 fuel ail-fired boiler B 1 (72 mmBftift maximum heat input) N/A N/A Not operating Natural gas/No.6 fuel oil-fired boiler B2 (24.76 mmBtu/hr maximum heat input) N/A N/A Not operating Textile roller printer (3,600 pounds of cloth per hour process capacity)consisting of: PR3 a) 8 print stations N/A N/A b) 1 natural gas direct-fired dryer (2 mmBtu/hr maximum heat input) Not operating Textile screen printer (3,600 pounds of cloth per hour process capacity)consisting of: PR4 a)8 rotary screen printing stations N/A N/A b) 1 natural gas direct-fired dryer (4.8 mmBtu/hr maximum heat input)with four zones Not operating Textile screen printer (3,600 pounds of cloth per hour process capacity)consisting of: a) 12 rotary screen printing stations PRS b) 1 natural gas direct-fired dryer N/A N/A (4.8 mmBtu/hr maximum heat input)with four zones Not operating Finishing range (5,760 pounds of cloth per hour process capacity)consisting of: TEN2 a) 1 pad applied finishing station N/A N/A b) 1 natural gas direct-fired(12.0 mmBtu/hr maximum heat input)eight zone tenter frame oven Not operating Finishing range (4,320 pounds of cloth per hour process capacity)consisting of: TEN3 a) 1 pad applied finishing station N/A N/A b) 1 natural gas direct-fired(6.0 mmBtu/hr maximum heat input)two zone tenter frame oven Operating at 80 yds/minute at—10% VE. One(1)bleach range and one(1)natural gas BLl and TEN4 direct-fired(8.5 mmBtu/hr maximum heat N/A N/A input)three zone tenter frame oven Neither was operating Emission Emission Source Control Control System SourceID_ Description System m Description CRl Steam heated cotton dye range N/A N/A Not operating Pigment range (4,800 pounds of cloth per hour process capacity)consisting of: PIGI a) I natural gas direct-fired dryer(4.0 N/A N/A mmBtu/hr maximum heat input)predryer b) 1 pad applied ink dyeing station c) 1 steam heated dryer Not operating Thermasol range (4,800 pounds of cloth per hour process capacity)consisting of: TRl a) 1 pad applied finishing station N/A N/A b) 1 natural gas direct-fired dryer (7.0 mmBtu/hr maximum heat input)dryer Not operating Shop lathe SLl (500 pounds per hour of rubber covered pad SL-IC Cyclone rolls) (15 inch diameter) Not operating BF-I Bagfilter (12 square feet of filter area) Starch storage silo SS 1 (22.5 tons per hour filling rate) In parallel with In parallel with Not operating BF-2 Bagfilter (12 square feet of filter area) OP-1CA Paper Panel Filter (6.55 square feet of filter area) Blendomat OP] (2,600 pounds per hour of cotton fiber) In series with In series with Not operating OP-1CB Rotary Drum Filter (46.5 square feet of filter area) Carding and drawing operation r45.u3rsquare Dram Filter FA /CARD] (2100 pounds per hour of cotton fiber) CARD 1-1 C feet of Not operating face area) Spinning operation Paper Filter FAC2 (266.8 square feet of (2100 pounds per hour of cotton fiber) AC2-1C Operating at 0% VE surface area) Emission Emission Source Control —Control System Source ID Description Syste _ ; I Description AC3 Three(3)weaving areas AC3-1C Paper Filter (1,870 pounds per hour of cotton yarn, (371.2 square feet of total capacity of AC3,AC4,and AC5) surface area)collecting C3 was operating at 0% VE.AC4,and from AC-3 C5 were not operating. AC4 AC44C Rotary Drum Filter (834.9 square feet of surface area)collecting AC-4. AC5 AC54C Rotary Drum Filter (545.3 square feet of surface area)collecting AC-5. NAPI Two(2)napping areas NAPl-IC Rotary Dram Filter (2,370 pounds per hour of cotton cloth,total (483.3 square feet of capacity of NAP I and NAP2) surface area)collecting Both were operating at—5% VE. from NAP 1. NAP2 NAP24C Rotary Drum Filter (142.1 square feet of surface area)collecting from NAP 2. Retention Pond N/A N/A Operating,no odor present INSPECTION SUMMARY: On 29 August 2018, I,Jeffrey Cole of NCDEQ, began the compliance inspection with an observation of the facility exhausts stacks from my vehicle prior to entering the facility. I did not notice any emissions that exceeded the permitted limits. I then entered the facility to conduct the compliance inspection. I first met with Ms. Shelly Wallace,Plant Environmental Manager and began by asking her to check the FacFinder,followed by a review of the required recordkeeping. There was one minor change to the Facfinder. This has been updated in IBEAM. Mr. Steven Burroughs,the Facility Mechanic produced the maintenance records on the facility's control devices and they all seemed in order. Ms. Wallace stated that the plant was operating normally and no changes had been made to sources or operations since the last inspection. She did mention that they had lost a few contracts including the specialty woven product that McDonalds used to clean their grills. The production of that product has since been sourced overseas. Ms.Wallace showed me the data from the required recordkeeping being accomplished for 2D .1100 and 2Q.315 under their permit. All monitored emissions for the last quarter(April 2018-June 2018)were below permitted levels. The annual report(received on I I January 2018) for CY2017 also showed that all monitored emissions were below permitted levels. I asked Ms. Wallace if her facility had had its natural gas supply curtailed in January 2018 as had many other facilities combusting natural gas? Ms. Wallace stated that the facility had been curtailed from 4 through 9 January 2018 and from 15 through 19 January 2018. However, since the facility's alternate fuel source is No. 6 fuel oil,which is so viscous that it needs to be heated with natural gas to make it flow (which they did not have at the time),the company chose during those curtailment times not to run production. I then proceeded on an inspection of all the facility's sources with Ms. Wallace and Mr. Burroughs,which included(in order): • Textile roller printer(PR3):Printer hasn't run in a while as foreign competition makes operating it impractical. • Textile screen printer(PR4) • Textile screen printer(PR5) • Finishing range(TEN2) • Finishing range(TEN3) • Bleach range and three zone Tenter Frame Oven(BLI and TEN4) • Pigment range(PIG I) • Thermasol range(TRI) • Two napping areas(NAPI and NAP2): Filter collects particulate and it drops out into building below filter. Waste material is collected and sold to another company. • Shop lathe(SLI) • Carding and drawing operation(ACl/CARDI) • Spinning operation(AC2) • Three(3)weaving areas(AC3,AC4,and AC5):AC4 and AC5's power has been cut and do not operate. • Starch storage silo(SS1) • Retention Pond(RP) • Blendomat(OP 1): Paper filters automatically roll to expose new filter when pressure drop gets close to 1.25". Blendomat will shut off when a paper filter roll needs to be replaced. Rolls are checked daily. • Natural gas/No. 6 fuel oil-fired boiler(B 1) • Natural gas/No. 6 fuel oil-Fred boiler(132) At the inspection's exit summary, I summarized my observations and told Ms. Wallace that I had not seen any deficiencies during my inspection. STIPULATION REVIEW: 1. 15A NCAC 2D .0202,"EMISSION INVENTORY REQUIREMENT"—Entire facility subject. Submit permit renewal application and EI at least 90 days prior to permit expiration. APPEARED IN COMPLIANCE—The facility's permit expires on 31 January 2019. The application and emission inventory will be due no later than 2 November 2018 with CY2017 data. The renewal application was received on 23 August 2018 with the EI being received on 20 August 2018. 2. 15A NCAC 2D .0503,PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS—The particulate emissions from boiler ID No.B 1 shall not exceed an emission rate of 0.33 lbs/mmBtu and boiler ID No. B2 shall not exceed 0.47 lbs/mmBtu. APPEARS IN COMPLIANCE—The facility burns NG exclusively with oil as a backup during curtailment. The worst case fuel is No. 6 at 2.1%sulfur(from current fuel certification), which emits 0.151bs/mmBtu. The AP-42 emissions factor for natural gas is 0.0071bs/mmBtu. 3. 15A NCAC 2D .0515,"PARTICULATE CONTROL REQUIREMENT"—Particulate emissions from miscellaneous sources shall not exceed those limits listed in the permit. APPEARED IN COMPLIANCE—Compliance was determined during the most recent permit review based on operating the source as described in the permit conditions. No changes have been made to their facility since the last permit review. 4. 15A NCAC 2D .0516,"SULFUR DIOXIDE EMISSIONS"—Sulfur dioxide emissions shall not exceed 2.3 lbs/mmBtu heat input. APPEARED IN COMPLIANCE—The worst-case fuel is No. 6 at 2.1%sulfur (current fuel certification), would emit S02 at rate of 1.7lbs/mmBtu. The fuel oil certifications indicated su firr content 1.62%the last several times it was purchased. The last purchase ofNo.6fue1 oil was 313114. 5. 15A 2D NCAC .0521,"VISIBLE EMISSIONS CONTROL REQUIREMENT"—Visible emissions from source ID Nos. PR4, PR5,TEN2,TEN3,TRl,BI,B2,BLl,TEN4, OP1, SLl, and SS1,manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged over a six-minute period. APPEARED IN COMPLIANCE—Only one of the emission sources was operating at the time of the walk through inspection. Prior to my plant internal inspection,I surveyed the roof stack and noted that this source's emissions appeared to not exceed 20 percent opacity. 6. 15A 2D NCAC .0521,"VISIBLE EMISSIONS CONTROL REQUIREMENT"—Visible emissions from source ID Nos. PIGI,PR3,AC1/CARD1, AC2,AC3,AC4,AC5,NAP and NAP2, manufactured before July 1, 1971, shall not be more than 40 percent opacity when averaged over a six-minute period. APPEARED IN COMPLIANCE—Two of the emission sources were operating at the time of the walk through inspection. Prior to my plant internal inspection, I surveyed the roof stack and noted that these source's emissions appeared to not exceed 40 percent opacity. 7. 15A NCAC 2D .0535,"NOTIFICATION REOUIREMENT"—The facility is required to notify DAQ if excess emissions occur for more than a 4-hour period caused by a breakdown or other abnormal condition. APPEARED IN COMPLIANCE—The technical contact, Ms. Wallace, stated that the facility has had no exceedances, breakdowns, or abnormal conditions requiring notification. 8. 15A NCAC 2D.0540,"FUGITIVE DUST CONTROL REQUIREMENT"—Fugitive dust emissions shall not cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. APPEARED IN COMPLIANCE—There was no dust on the roadways about the facility. The facility contact, Ms. Wallace, stated that they have not received any dust complaints since the last inspection. 9. 15A NCAC 2D .0611."CYCLONE REQUIREMENTS"—Annual&periodic I&M and recordkeeping requirements. APPEARED IN COMPLIANCE—The facility inspects its single cyclone on a monthly basis. Logs indicate I&M is done by the facility mechanic, Mr. Steven Burroughs. The cyclone was last checked on 15 August 2018. The last annual inspection was done on 3 July 2018. 10. 15A NCAC 2D .0611."FABRIC FILTER REQUIREMENTS"—Annual&periodic I&M and recordkeeping requirements. APPEARED IN COMPLIANCE—The facility inspects rotary drum filters and bagfilters on a monthly basis. Logs indicate I&M is done by the facility mechanic, Mr. Steven Burroughs. The bagfilters were last checked on 15 August 2018. The last annual internal inspection was done on 3 July 2018. 11. 15A NCAC 2D .0958.WORK PRACTICES FOR SOURCES OF VOC's—Requirements include closed storage of solvent-laden rags, spill management,minimizing splash, generally reducing evaporation. APPEARS IN COMPLIANCE—Did not observe any violation(s). This rule has changed, so this condition no longer applies to facilities located in attainment areas. This stipulation will be removed at the next opening of the permit as it is only required in areas of nonattainment. 12. 15A NCAC 2D .1100.TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING REOUI REMENTS-Pursuant to 15A NCAC 21) .1100 and in accordance with the approved application for an air toxic compliance demonstration,the permit limit shall not be exceeded. Record daily;report annually. APPEARED IN COMPLIANCE -Records showed TAP limits had not been exceeded. Records are maintained for the maximum hourly rate of ammonia input to each printer(ID Nos. PR3, PR9, and PR5)for each day ofproduction, and the maximum hourly rate offormaldehyde input to each tenter frame (ID Nos. TEN2, and TENS)for each day ofproduction. Usage and emissions reports are provided to FRO annually. The last annual report containing this data was submitted on 11 January 2018 and appeared to be complete. Ammonia highest emission rate for the last quarter (April 2018-June 2018)for PR5 = 1.57lb/hr (limit: <2.861b/hr). Formaldehyde highest emission rate for the last quarter for(TENS) =0.0961b/hr(limit: <0.2281b/hr) and for(TEN2) = 0.068 lb/hr (limit: <0.30lb/hr). Note: The maximum hourly emissions (listed above) are calculated by dividing the worst case dye chemicals(i.e., having the highest concentrations of ammonia or formaldehyde, respectively) by the total hours of operation. This would mean the emissions rates listed above would bias higher than actual emissions. I again asked the facility contact if there was anyway they could record and report more realistic emission rates of ammonia and formaldehyde. The facility contact stated that while they would review and modify as appropriate to provide more realistic maximum hourly emission rates than have been previously reported by the facility annual reports there are no firm plans to change the way the data is calculated. 13. 15A NCAC 2D .1806."CONTROL AND PROHIBITION OF ODOROUS EMISSIONS." No objectionable odors beyond property line. APPEARED IN COMPLIANCE-No objectionable odors were noted during the inspection; the facility contact, Ms. Wallace, stated that no complaints have been received since the last inspection. 14. 15A NCAC 20 .0315,LIMITATION TO AVOID 15A NCAC 20.0501—Facility-wide emissions of PM10, SO2,and NOx shall each be less than 100 tons per consecutive 12-month period; sulfur content of the No. 6 fuel oil 5 2.1%by weight; combust:S 601,000 gallons of No. 6 fuel oil during any consecutive 12-month period. The amount of fuel oil combusted shall be totaled monthly and reported annually. Fuel certifications shall also be kept onsite. APPEARS IN COMPLIANCE—Since the last inspection the facility has not combusted any fuel oil The last annual report containing this data was submitted on 11 January 2018 and appeared to be complete. 15. 15A NCAC 2D .1111,AVOIDANCE OF BOILER NESHAP(GACT 6J)—Would-be subject sources are boilers Bl &B2. Facility avoids applicability of this rule by burning Natural Gas,with fuel oil only as back-up during emergencies,testing and curtailment. Keep records of fuel oil usage and reason for usage. Notify DAQ within 30 days of switch to fuel oil outside of emergencies,testing and curtailment. APPEARS IN COMPLIANCE—Since the last inspection the facility has not combusted any fuel oil. The facility had their natural gas curtailed from 4 through 9 January 2018 and from 15 through 19 January 2018. However, since the facility's alternate fuel source is No. 6fuel oil which is so viscous that it needs to be heated with natural gas to make it flow(which they did not have at the time). During those curtailment times the company chose not to run any production. 16. 15A NCAC 20. 0317,AVOIDANCE OF PREVENTION OF SIGINIFICANT DETERIORATION-Discharge into the atmosphere less than 250 tons of PMio and S02, respectively,per consecutive twelve month period. APPEARED IN COMPLIANCE- The facility has met the requirements of stipulation 15A NCAC 2Q.0315, Limitation to Avoid 15A NCAC 2Q.0501, and therefore has complied with this rule. NON-COMPLIANCE HISTORY SINCE 2010 20 June 2014 NOD for Visible Emissions for failure to re-establish"normal"VE for emission sources by 7 March 2014. 10 May 2013 CAI VE Monitoring and Record Keeping 9 Nov 2012 NOV for VE>20% 112R STATUS: The facility does not store or use any of the listed chemicals above the threshold quantities, and is not required to maintain a written Risk Management Plan(RMP). CONCLUSIONS AND RECOMMENDATIONS: Wade Manufacturing Co.-Wadesboro(0400016)appeared to be IN COMPLIANCE with their current air permit at the time of inspection. Pink Sheet Notes: • Remove 2D .0958 during permit renewal since it applies only in non-attainment or maintenance areas and Richmond County is in attainment. \Iv w 1. ♦ lip* CHht� ?I�tji�Rbugl €iE'➢ !'B; owlim, J i91 a� x � WIWI rep- Y+ 'r1 -ct '�lggcctt.�kr�t( +awysitat'u �$Jatuitt' 1�l�itt• �,�o�t�r�`�Mr.>,r;�1�134t u1�1��` ° �ieillu�b''tnlw'�,`,'i+�1_ ,C` �? 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