HomeMy WebLinkAboutAQ_F_0400016_20150527_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: 6/15/2015
Facility Data Permit Data
Wade Manufacturing Co-Wadesboro Permit 03577/T17
Highway 74 East Issued 2/6/2014
Wadesboro,NC 28170 Expires 1/31/2019
Lat: 34d 57.8720m Long: 80d 2.6476m Classification Title V
SIC: 2261 /Finishing Plants,Cotton Permit Status Active
NAICS: 313311 /Broadwoven Fabric Finishing Mills Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
David Bruton Bernard Hodges David Bruton
PlantIE President PlantIE
(704)694-2131 (704)694-2131 (704)694-2131
Compliance Data
Comments:
Inspection Date 05/27/2015
� / Inspector's Name Jeffrey D. Cole
Inspector's Signature: ( Operating Status Operating
Compliance Code Compliance-inspection
( / Action Code FCE
Date of Signature: / . 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
2012 13.17 0.0200 5.17 13.44 4.29 13.17 1557.10
*Highest HAP Emitted(in pounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
11/09/2012 NOV 2D .0521 Control of Visible Emissions 11/19/2012
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. (Drive past facility and take a left at the stop sign.Vantage point from neighborhood is perfect for
VE observations).
NOTE: Mr.Bruton normally takes lunch from 11:00 AM to Noon,so plan the inspection accordingly.
NOTE:Main office closed from Noon to 1:00 PM. Call Mr. Bruton on his extension(x222)and he will let you in.
SAFETY:
Standard DAQ FRO Safety Gear. Main safety concert is slips trips and falls from uneven and slippery floors,stairs,
and forklift traffic.
FACILITY DESCRIPTION:
Wade Manufacturing is a Title V facility based on the burning of No. 6 fuel oil(SO2)and the VOC emissions
associated with the textile manufacturing process(bleaching,dying).Wade Manufacturing makes,dyes and prints
cotton and polyester/cotton blend fabric. The process includes bleaching,dying,printing,and finishing of cloth.The
facility does twist some yam for their Rockingham plant and does weave a specialty product for McDonalds to clean
their grills.All other yarn spinning,twisting,and weaving is now done at the Rockingham plant. 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.03577T17, issued 6 February 2014,with an
expiration date of 31 January 2019.
Emnlovees: 150-175
Hours: 4 or 5 days a week,7 AM to 3 PM.
Through-nut:
Note: When asked for production throughput amounts the facility contact stated that they were about the same as the
year before but could not offer specifics. The throughputs recorded in the 6/19/14 compliance inspection were:
Year Throughput in Average weight of Average weight range of
million yards fabric d/Ib fabric d/Ib
2013 6.25 1.55 0.89-3.4
Emission Sources:
�t'
B 1 One natural gas/No.6 fuel oil-fired N/A N/A
boiler(72 million Btu per hour heat
input capacity)(installed in 1995)
Operating combusting NG. VE 0%.
B2 One natural gas/No.6 fuel oil-fired N/A N/A
boiler(24.76 million Btu per hour heat
input)
Not operable without many new parts.
PR3 One textile roller printer (3,600 N/A N/A
pounds of cloth per hour process
capacity)consisting of:
a)8 print stations
b) 1 natural gas-fired dryer(2 million
Btu per hour heat input)
Not operable. Many parts have been
removed from the roller printer.
s
lE4
I
One textile screen printer (3,600 N/A N/A
pounds of cloth per hour process
capacity)consisting of:
a)8 rotary screen printing stations
b) 1 natural gas-fired dryer(4.8
million Btu per hour heat input)with
four zones
Not operating during inspection.
PR5 One textile screen printer(3,600 N/A N/A
pounds of cloth per hour process
capacity)consisting of:
a) 12 rotary screen printing stations
b) 1 natural gas-fired dryer(4.8
million Btu per hour heat input)with
four zones
On Standby-Not operating during
inspection. Maintenance was being
performed before it could be put back
online.
TEN2 One finishing range(5,760 pounds of N/A N/A
cloth per hour process capacity)
consisting of:
a) I pad applied finishing station
b) 1 natural gas-fired 12.0 million Btu
per hour eight zone tenter frame oven
Operating at 61.7 yards/minute.
Temperature293-361Y.. Setpoint
370Y. When we observed the stack
later in the inspection, we saw VE 0%.
TEN3 One finishing range(4,320 pounds of N/A N/A
cloth per hour process capacity)
consisting of:
a) 1 pad applied finishing station
b) 1 natural gas-fired 6.0 million Btu
per hour two zone tenter frame oven
Operating at 59 yards/minute.
Temperature 370°F. Setpoint 3747..
When we observed the stack later in
the inspection, we saw VE 0%.
BLl and One bleach range and one natural gas N/A N/A
TEN4 direct-fired 8.5 million Btu per hour
three zone finishing range
_ Operating at 83 yards/minute.
Finishing solid white cotton.
Temperature 374 Y. Set point 375Y..
When we observed the stack later in
the inspection, we saw VE 0%.
CRl Steam heated cotton dye range N/A N/A
Operating at 40 yards/minute. When
we observed the stack later in the
inspection, we saw VE 0%.
�^� 1 S zrz� "i �£ e'� v.4' sly � l'3•IIl �.' `., Yy F {+ s
PIG One pigment range(4,800 pounds of N/A N/A
cloth per hour process capacity)
consisting of:
a) 1 natural gas direct-.fired 4.0
million Btu per hour predryer
b) 1 pad applied ink dyeing station
c) 1 steam heated dryer
Not operating during inspection.
TR1 One thermasol range(4,800 pounds of N/A N/A
cloth per hour process capacity)
consisting of.
a) 1 pad applied finishing station
b) 1 natural gas-fired 7.0 million Btu
per hour dryer
Not operating during inspection.
Rarely operates.
SLl One shop lathe(500 pounds per hour SL IC One Cyclone(15 inch
of rubber covered pad rolls) diameter)
Not operating
SSl One starch storage silo(22.5 tons per BF 1 One Bagfilter(12 square feet
hour filling rate) of filter area)
Empty and has not been used in years in parallel with
but still at facility. BF 2 One Bagfilter(12 square feet
of filter area)
OPl One blendomat(2600 pounds per hour OP 1CA One Paper Panel Filter(6.55
of cotton fiber) square feet of filter area)
Operating. Paper filters automatically in series with
roll to expose new filter when pressure OP 1 CB One Rotary Drum Filter(46.5
drop gets close to 1.25". Blendomat square feet of filter area)
will shut off when a paper filter roll
needs to be replaced. Rolls are
checked daily. VE 0%.
ACl/CARD1 One carding and drawing operation CARDI-IC One Rotary Drum Filter
(2100 pounds per hour of cotton fiber) (545.3 square feet of surface
Operating. VE 0%. area)
Drum filter collects all
particulate and drops out
indoors. Wade collects this
waste and sells it. Operates
in a rage of 1.5 to 2.5 inches
of H20.
may_ l E .Yh
3 nCyPPnt�'
K t O x D
t
AC2 One spinning operation(2100 pounds AC2-IC One Paper Filter(266.8
per hour of cotton fiber) square feet of surface area
Operating. VE 0%.
6 paper filters automatically
roll to expose new filter when
pressure drop gets close to
1.25". Spinning will shut off
when a paper filter roll needs
to be replaced Rolls are
checked daily. Gauge setting
shows that it operates in a
rage of 1 to 2 inches o Hz0.
AC3 One weaving operation(1870 pounds AC34C One Paper Filter(371.2
per hour of cotton yam,total capacity square feet of surface area)
of AC3,AC4,and AC5) collecting from AC-3.
Not operating.
AC4 AC3and AC5's power has been cut AC44C One Rotary Drum Filter
and do not operate. AC4 was (834.9 square feet of surface
operating in the weaving area. 10 area)collecting AC-4.
paper filters.Air is then recycled into
the indoor air supply. VE 0%.
AC5 Not operating. AC5-lC One Rotary Drum Filter
(545.3 square feet of surface
area)collecting AC-5.
NAP1 One napping operation(2370 pounds NAP1-IC One Rotary Drum Filter
per hour of cotton cloth,total capacity (483.3 square feet of surface
of NAP 1 and NAP2) area)collecting from NAP 1.
11 nappers total. 6 napping operating
and 5 not operating. Filter collects
NAP2 particulate and it drops out into NAP2-IC One Rotary Drum Filter
building below filter. Waste material is (142.1 square feet of surface
collected and sold to another area) collecting from NAP 2.
company.
RP Retention pond N/A N/A
Operating. VE 0%.No offsite odor.
Insignifcant/Exempt Sources:
The facility has three insignificant/exempt sources:two steam heated spasher dryers(I-SD 1 and I-SD2)and one dye
finish mixing room(I-DFM).
The facility also has three electric air compressors and 3 No. 6 fuel tanks(2) 12,000 gallon tank above ground and
(1)20,000 gallon underground.
COMPLIANCE INSPECTION SUMMARY:
On 27 May 2015,Robert Hayden and I,Jeffrey Cole,both of NCDEQ,began a compliance inspection with a check
of the roof from each side of the plant;there were no apparent exceedances. We then met with Mr.David Bruton
and began with a FacFinder check and a review of the required recordkeeping. The records are complete,i.e.,there
are entries on each day of operation,but are highly suspect,as every day is identical and nothing is ever out of the
ordinary or repaired,whereas issues are often noted by DAQ inspectors passing by the facility.
We then asked to speak with the plant manager,Mr. Hodges, and discussed the merits and suitability of changing his
permit class from Title V to Synthetic Minor. He was very interested and asked that I send him the required forms,
which I did on returning to the office.
We then went to the roof to confirm the equipment list and to check opacity.Through pictures, sketches,video and
input from Mr.Bruton,we confirmed the equipment list and have produced a sketch of the emission points to aid
fixture inspectors.It was difficult to tell which sources were operating,but there were no opacity issues. I then asked
Mr.Bruton to show me how he does his opacity checks;from the location he identified,many sources could not be
seen. We summarized our observations,emphasized the importance of legitimate daily checks and said we would
provide the reclassification forms and assist in their completion.
SPECIFIC LIMITATIONS AND CONDITIONS
2.1- Emission Sources and Control Devices Specific Limitations and Conditions
A. two(2)natural gas/No.6 fuel oil-fired boilers(ID Nos.Bl,112)
1. 15A NCAC 2D.0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS-21) .0503,Particulates from fuel burning Heat Exchangers. Heat input from boiler Bl and
0.47 lb/mmBtu heat input from boiler B2.
APPEARED IN COMPLIANCE—The worst case fuel is No. 6 at 2.1%su fur(from current fuel certification), which
emits 0.16 lbs/mmBtu.
2. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES-21)
.0516, SO2 from Combustion Sources. Limit is 2.3 lbshnmBtu. Keep fuel oil supplier records. Semiannual
reporting(fuel certs).
APPEARED INCOMPLIANCE: The worst case fuel is No. 6 at 2.1%suer(from current fuel certification), which
emits 2.1 lbs/mmBtu. The fuel oil certifications indicated su f r content 1.61%the last several times it was
purchased The lastpurchase ofNo.6fuel oil was 313114.
3. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-Visible emissions from these sources
(ID Nos.Bl,112)shall not be more than 20 percent opacity when averaged over a six-minute period.
APPEARED INCOMPLIANCE: No visible emissions observed during the inspection from this Bl, B2 not
operating. Logbook indicated daily VE observation recorded and indicated compliance. Facility was combusting
NG. Semi-annual report turned in on time and appeared in compliance.
4. 15A NCAC 2Q.0317:AVOIDANCE CONDITIONS(Avoidance of 15A NCAC 2D.0530:
PREVENTION OF SIGINIFICANT DETERIORATION)-In order to avoid applicability of 2D .0530(g),these
emission sources(ID Nos.Bl,112)shall discharge into the atmosphere less than 250 tons of S02 per consecutive
twelve month period.Monthly records of the amount of fuel used and the sulfur content,including certification of
the fuel,in a logbook. Monthly SO2 emissions calculations are also performed. Semi-annual summary report.
APPEARED INCOMPLIANCE: Records indicated SO2 emissions less than 250 tons.As of May 2015, —0.025 TPY.
The facility calculates monthly SO2 emissions and records that in the logbook. Semi-annual reports received on
time, indicate compliance.
5. 15A NCAC 2Q.0317:AVOIDANCE CONDITIONS(Avoidance of 40 CFR Part 63 Subpart JJJJJJ)
Because both boilers(ID Nos. B1,112)are considered gas-fired boilers,provided liquid fuel only during periods of
gas curtailment,gas supply interruption, startups,or periodic testing on liquid fuel. Record times and reasons for oil
combustion.
APPEARED IN COMPLIANCE: Only B 1 was operating.The boilers combust natural gas. The facility was sent an
email that they were being curtailed/"operational flow order"two times(1/7/15 to 1/12/15 and 2/14/15 to 2/21/15
by Piedmont NG.The facility keeps records of the time they use fuel oil and what it is for and have copies of the
emails they received.
B. One natural gas-fired textile roller printer(ID No.PR3)and one natural gas-fired pigment range(ID
No.PIG1)
1. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES-
2D.0515,Particulates from Miscellaneous Industrial Processes. Limit is based on throughput rate and weight.
APPEARED INCOMPLIANCE: Compliance determined during permit review. Plant appears to be operating as
permitted
2. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES-2D
.0516, S02 from Combustion Sources. Limit is 2.3 Ibs/mmBtu. Keep fuel oil supplier records. Semiannual
reporting(fuel certs).
APPEARED IN COMPLIANCE: The worst case fuel is No. 6 at 2.1%sulfur(from current fuel certification), which
emits 2.1 lbs/mmBtu.
3. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-Visible emissions from these sources
(ID Nos.PR3,PIGI)shall not be more than 40 percent opacity when averaged over a six-minute period.No
reporting/monitoring/recordkeeping for S02 emissions from natural gas.Once a day,every day,while firing No.6
fuel oil,observe the emission points for VE above normal.No more than three absences in a calendar year.Re-
establish"normal'for the sources and record the results and the operating temperature(if applicable)that were used
to determine"normal'to DAQ on or before March 7,2014.If VE above normal, correct or Method 9 for 12 minutes
at<40%to demonstrate compliance.VE"normal' logbook. Semi-Annual summary report.
APPEARED INCOMPLIANCE: PR3 and PIGI processes were not operating during the inspection. Facility was
combusting NG on the day of the inspection.Daily observation/record done by Mr.Bruton. Recorded observations
indicate compliance. Semi-annual reports received on time, indicate compliance. Company sent response to NOD
re-establishing normal on 11 July 2014.
C. Two natural gas-fired textile screen printers(ID Nos.PR4 and PR5),two natural gas-fired tenter
frames(ID Nos.TEN2,and TEN3),one natural gas-fired thermosol range(ID No.TRI),and one bleaching
range with tenter frame(ID Nos.BLI and TEN4)
1. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES-
2D.0515,Particulates from Miscellaneous Industrial Processes. Limit is based on throughput rate and weight.
APPEARED IN COMPLIANCE: Compliance determined during permit review. Plant appears to be operating as
permitted.
2. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES-2D
.0516, S02 from Combustion Sources. Limit is 2.3 lbs/mmBtu. Keep fuel oil supplier records. Semiannual
reporting(fuel certs).
APPEARED INCOMPLIANCE: The worst case fuel is No. 6 at 2.1%sulfur(from current fuel certification), which
emits 2.1 lbs/mmBtu.
3. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-Visible emissions from these sources
(ID Nos.PR4,PR5,TEN2,TEN3,TEN4,TRl,BLI)shall not be more than 20 percent opacity when averaged
over a six-minute period.No reporting/monitoring/recordkeeping for SOz emissions from natural gas. Once a day,
every day,while firing No.6 fuel oil,observe the emission points for VE above normal.No more than three
absences in a calendar year. If VE above normal, correct or Method 9 for 12 minutes at<20%to demonstrate
compliance. VE"normal'logbook. Semi-Annual summary report.
APPEARED IN COMPLIANCE: VE= 0%opacity from the tenter frame stacks during the inspection. Daily
observationlrecord done by Mr. Bruton. Facility was combusting NG. PR4,PR5, and TRI not operating. Semi-
annual reports received on time, indicate compliance. Company sent response to NOD re-establishing normal on
ll July 2014. All reading in logbook indicated that emissions between Jan 2015 and April2015 from each stack
were always either normal or that the emission source using the stack was not operational in between Jan 2015 and
April 2015.
D. One shop lathe(ID No. SLl)with one associated cyclone(ID No.SL1C),one starch storage silo(ID
No.SS1)with two associated bagfilters(ID Nos.BFl and BF2),and one blendomat operation(ID No. OPi)
with one associated paper panel filter and one associated rotary drum filter(ID Nos.OP1CA and OP1CB)
1. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES-
2D.0515,Particulates from Miscellaneous Industrial Processes. Limit is based on throughput rate and weight.
APPEARED IN COMPLIANCE: Compliance determined during permit review. All sources last inspected and
cleaned on 13 May 2015. Plant appears to be operating as permitted
2. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-Visible emissions from these sources
(ID Nos.SLl,SSl,OPl)shall not be more than 20 percent opacity when averaged over a six-minute period. Once a
day,every day,while firing No. 6 fuel oil,observe the emission points for VE above normal.No more than three
absences in a calendar year. If VE above normal, correct or Method 9 for 12 minutes at<20%to demonstrate
compliance. VE"normal'logbook. Semi-Annual summary report.
APPEARED IN COMPLIANCE: Daily observationlrecord done by Mr. Bruton. Recorded observations indicate
compliance. Semi-annual reports received on time, indicate compliance. VE=0%on the day of the inspection. SLI
and SSI not operating in several years. Company sent response to NOD re-establishing normal on ]]July 2014,
E. One carding and drawing operation(ID No.ACl/CARDI)with one associated rotary drum filter(ID
No.CARD1-IC),one spinning operation(ID No.AC2)with one associated paper filter(ID No.AC2-IC),one
weaving operation(ID Nos.AC3,AC4,and AC5)with one associated paper filter and two rotary drum filters
(ID Nos.AC3-IC,AC4-IC,and AC5-IC),and one napping operation(ID Nos.NAP1 and NAP2)with two
associated rotary drum filters(ID Nos.NAPl-IC and NAP2-IC)
1. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES-
2D.0515,Particulates from Miscellaneous Industrial Processes. Limit is based on throughput rate and weight.
APPEARED IN COMPLIANCE: Compliance determined during permit review. The facility inspects rotary drum
filtes and bagfilters on a monthly basis. Logs indicate I&M is done by the facility mechanic Steven Burroughs. Last
checked on 13 May 2015. Internal inspections were also done on 13 May 2015. Plant appears to be operating as
permitted
2. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-Visible emissions from these sources
(ID Nos.ACl/CARD1,AC2 through AC5,NAPI,NAP2)shall not be more than 40 percent opacity when
averaged over a six-minute period. Once a day,every day,while firing No. 6 fuel oil,observe the emission points
for VE above normal. No more than three absences in a calendar year. If VE above normal,correct or Method 9 for
12 minutes at<20%to demonstrate compliance. VE"normal'logbook. Semi-Annual summary report.
APPEARED IN COMPLIANCE: No visible emissions observed during the inspection. Daily observationlrecord
done by Mr. Bruton. Recorded observations indicate compliance. Semi-annual reports received on time, indicate
compliance. The weaving operations(ID No.AC3 and ACS)were not operated for the last 5 years. Company sent
response to NOD re-establishing normal on 11 July 2014.
2.2- Multiple Emission Source(s)Specific Limitations and Conditions
A. One natural gas-Bred textile roller printer(ID No.PR3),one natural gas-fired pigment range(ID No.
PIGI),two natural gas-fired textile screen printers(ID Nos.PR4 and PR5),two natural gas-fired tenter
frames(ID Nos.TEN2,and TEN3),one natural gas-fired thermosol range(ID No.TRI),one bleach range
and natural gas-fired finishing range(ID Nos.BLl and TEN4),and one steam heated cotton dye range(ID
No.CRl)
1. 15A NCAC 2D.0958: WORK PRACTICES FOR SOURCES OF VOLATILE ORGANIC
COMPOUNDS for all sources that use volatile organic compounds(VOC)as solvents, carriers,material processing
media,or industrial chemical reactants,or in similar uses that mix,blend, or manufacture VOCs,or emit VOCs as a
product of chemical reactions the Permittee shall follow all VOC work practices.Monthly visual inspections
recorded in a logbook. Semi-annual summary report.
APPEARED IN COMPLIANCE: The plastic lids to the drums currently in use are covered Mr. Bruton stated that
this regulation requires continual oversight to ensure compliance. Monitoring records are complete and indicate
compliance. Last inspection completed 21 May 2015. Semi-annual report submitted on time and appeared in
compliance.
B. One natural gas-fired textile roller printer(ID No.PR3),one natural gas-fired pigment range(ID No.
PIGI),two natural gas-fired textile screen printers(ID Nos.PR4 and PR5),three natural gas-fired tenter
frames(ID Nos.TEN2,and TEN3),one natural gas-fired thermosol range(ID No.TRl),and one bleach
range and natural gas-fired finishing range(ID Nos.BLl and TEN4)
1. 15A NCAC 2Q. 0317 AVOIDANCE CONDITIONS(Avoidance of 15A NCAC 2D.0530:
PREVENTION OF SIGNIFICANT DETERIORATION)-In order to avoid applicability of 2D.0530(g),the
above emission sources(ID Nos.PR3 through PR5,PIGI,TEN2 through TEN4,TRl,BLl)shall discharge into
the atmosphere less than 250 tons of volatile organic(VOC)compounds per consecutive twelve month period.
Calculations of VOC emissions per month shall be made at the end of each month and recorded in a logbook. Semi-
annual report.
APPEARED IN COMPLIANCE: VOC emissions are far below than 250 tons. The facility calculates monthly VOC
emissions and records that in the logbook. 2015 VOC emissions as of May 2015 was 1.52 TPY. The highest month in
the last 12 months was in April 2015 with 0.1 TPY. Semi-annual reports received on time, indicate compliance.
Emission sources PR3, PR4, PR5, and TRl are not in operation.
C. All emission sources
State-enforceable Only
1. 15A NCAC 2D.1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS-The
Permittee shall not operate the facility without implementing management practices or installing and operating odor
control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to
objectionable odors beyond the facility's boundary.
APPEARED INCOMPLIANCE: No odors were detected at the facility property line.Neither DAQ nor the facility
has received any complaints in the last 12 months.
State-enforceable Only
2.3- TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING REQUIREMENTS-
Pursuant to 15A NCAC 2D A 100 and in accordance with the approved application for an air toxic compliance
demonstration,the following permit limit shall not be exceeded:
Tenter frame(ID No.TEN2) Ammonia 0.30 pounds per hour
Formaldehyde 0.128 pounds per hour
Methyl isobutyl ketone 6.32 pounds per hour
Styrene 0.21 pounds per hour
Tenter frame(ID No.TEN3) Ammonia 0.228 pounds per hour
Formaldehyde 0.104 pounds per hour
Methyl isobutyl ketone 6.32 pounds per hour
Styrene 0.21 pounds per hour
Tenter frame(ID No.TEN4) Ammonia 0.004 pounds per hour
Boiler(ID No.B1) Formaldehyde 0.0204 pounds per hour
Boiler(ID No.132) Formaldehyde 0.0007 pounds per hour
Printer(ID No.PR3) Ammonia 3.36 pounds per hour
Formaldehyde 0.084 pounds per hour
Styrene 1.24 pounds per hour
Printer(ID No.PR4) Ammonia 2.86 pounds per hour
Formaldehyde 0.084 pounds per hour
Styrene 1.24 pounds per hour
Printer(ID No.PR5) Ammonia 2.86 pounds per hour
Formaldehyde 0.084 pounds per hour
Styrene 1.24 pounds per hour
Pigment range(ID No.PIG I) Formaldehyde 0.0008 2ounds per hour
Thermosol range(ID No. TRl) Ammonia 1.12 pounds per hour
Formaldehyde 0.002 pounds per hour
Retention pond(ID No.RP) Ammonia 0.0012 pounds per hour
Formaldehyde 0.0016 poun s per hour
1.To ensure compliance with the above limits,the following restrictions shall apply: (i)The input rate of ammonia
to the roller printer(ID Nos.PR3)shall not exceed 3.35 pounds per hour,(ii)The input rate of ammonia to each
screen printer(ID Nos.PR4 and PR5)shall not exceed 2.85 pounds per hour, (iii)The input rate of formaldehyde
to the tenter frame(ID Nos. TEN3)shall not exceed 0.104 pounds per hour,and(iv)The input rate of formaldehyde
to the tenter frame(ID No.TEN2)shall not exceed 0.126 pounds per hour.
2.Daily Records:(i)The maximum hourly rate of ammonia input to each printer(ID Nos.PR3,PR4,PR5)for each
day of production,(ii)The maximum hourly rate of formaldehyde input to each tenter frame(ID Nos.TEN2,
TEN3)for each day of production.
3. Quarterly Reporting: (i)The maximum hourly rate of ammonia input to each printer(ID Nos.PR3,PR4,PR5)
for each day of production,(ii)The maximum hourly rate of formaldehyde input to each tenter frame(ID Nos.
TEN2,TEN3)for each day of production.
APPEARED IN COMPLIANCE: Records showed limits had not been exceeded Records are maintained for the
maximum hourly rate of ammonia input to each printer(ID Nos. PR3, PR4, and PR5)for each day ofproduction,
and the maximum hourly rate ofform aldehyde input to each tender frame(ID Nos. TEN2, and TEN3)for each day
ofproduction. Mr. Bruton keeps records for each day. Usage and emissions reports are provided to FRO
semiannually. Because of the facility's greatly reduced operations, TAP emissions are far below the limits.
Ammonia highest emission rate for the last quarter(Jan 2015-March 2015)for PR5= 1.92 lb/hr. Formaldehyde
highest emission rate for the last quarter for(TEN3) =0.096lb/hr and for(TEN2) =0.088 lb/hr. Between Jan 2015-
March 2015, PR3 and PR4 were not operating. Quarterly reporting was submitted on time and appeared to be in
compliance.
Note:these maximum hourly emissions 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.
112R Status: The facility does not use or store subject compounds in quantities that would require a written risk
management plan under the clean air act section 112(r).
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.
9 May 2013-CAI VE Monitoring and Record Keeping
9 Nov 2012—NOV for VE>20%
COMMENTS AND RECOMMENDATIONS:
Based on the observations made during the 27 May 2015 inspection,Wade Manufacturing appeared to be operating
in compliance with all regulations outlined in their current air permit.
PINK SHEET: None