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HomeMy WebLinkAboutAQ_F_0400016_20140619_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: 06/25/2014 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 NAILS: 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 MACT Part 63: Subpart 6J Plant IE President Plant IE (704)694-2131 (704)694-2131 (704)694-2131 Compliance Data Comments: Inspection Date 06/19/2014 Inspector's Name Maureen Conner Inspector's Signature: Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: Z 5 J Urw On-Site Inspection Result Deficiency Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP f 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 2011 13.99 1.02 5.45 11.56 4.43 13.98 1515.10 *Highest HAP Emitted(in ounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date I t/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 Page of 12 DIRECTIONS: From downtown Fayetteville,take Raeford Road,Hwy 401, south to Wagram, —32 miles. Just past 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) SAFETY: Standard DAQ FRO Safety Gear.Main safety concert is slips trips and falls from uneven and slippery floors and forklift traffic. FACILITY DESCRIPTION: Wade Manufacturing is a Title V facility based on the burning of No. 6 fuel oil (S02)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 yarn 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. Employees: 150 Hours: 4 days a week,7am-4 pm. Through-put: 2013: 6.25 million yards through bleaching(almost everything goes through bleaching) Cloth weight is averages at 1.55 yards/lb,running from 0.89-3.4 yrd/lb. ,��{ u rnusrun Sd� e :aCoppfrol Control Il Yxee '.f '1 k 3• $ .�,i2 { DrYtee Y r Deserphitn Desertption 1D 111e 1 B1 One natural gas/No. 6 fuel oil-fired N/A N/A boiler(72 million Btu per hour heat input capacity) Combusting NG. 0% VE. One natural gas/No. 6 fuel oil-fired N/A N/A B2 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. Page 3 of 12 mbs Tum�ssion Sore nLrol `Co'n' I Devfce " DscriptAtlzr ""," ;ua Qrice Aescri tr n .g )",No. PR4 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 Operated most days. Can print 8 colors at a time.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 Operating at 45 yards/minute. Printing 5 colors(able to do up to 12)of blue and green stripes on cotton. VE 10%. TEN2 One finishing range(5,760 pounds of N/A N/A cloth per hour process capacity) consisting of: a) 1 pad applied finishing station b) 1 natural gas-fired 12.0 million Btu per hour eight zone tenter frame oven Operating at 75.7 yards/minute. VE 5%. Finishing solid Black cotton. Temperature 369-373 7. Set point 385°F. 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 96 yards/minute. VE 10%. Finishing solid bright blue cotton. Temperature 372-383 Y. Set point 3857. 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 92 yards/minute. VE 10%. Finishing solid white cotton. Temperature 375 'F. Set point 385Y. CRl Steam heated cotton dye range N/A N/A Operating at 48 yards/minute. Sizing a tan neutral poly-cotton blend. VE 5%. Page 4 of 12 ,� ssipp ' =a Emts pnSoYtnc GonL CoutrnlUe�ce urce "1)ephon 1 ID " Aescthptiop PIGI One pigment range(4,800 pounds of N/A N/A cloth per hour process capacity) consisting of: a) 1 natural gas direct-fued 4.0 million Btu per hour predryer -_ b) 1 pad applied ink dyeing station c) 1 steam heated dryer Not operating during inspection. TRl 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) I 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 1C One Cyclone(15 inch of rubber covered pad rolls) diameter) Not operating since facility let go of their shop guy. Used to be used to trim down rubber rollers when they got hard. This is now outsourced. 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 1CB One Rotary Drum Filter(46.5 drop gets close to 1.25".Blendomat square feet of filter area) will shut off when a paperfilter roll needs to be replaced. Rolls are checked daily. ACl/CARDI One carding and drawing operation CARDl 1C One Rotary Drum Filter (2100 pounds per hour of cotton fiber) (545.3 square feet of surface Operating. Drum filter collects all area) particulate and drops out indoors. Wade collects this waste and sells it. AC2 One spinning operation(2100 pounds AC2-lC One Paper Filter(266.8 per hour of cotton fiber) square feet of surface area Operating. 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. Page 5 of 12 Enuss�otlmrssion SoYirce:' Control Control Dee Source ;' Deorce Aesc►3ighon Descptiprl AC3 One weaving operation(1870 pounds AC3-lC One Paper Filter(371.2 per hour of cotton yarn,total capacity square feet of surface area) of AC3,AC4,and AC5) collecting from AC-3. AC4 AC3and AC5's power has been cut AC4-lC 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=O%. One Rotary Drum Filter AC5 AC5-1C (545.3 square feet of surface area)collecting AC-5. NAPI One napping operation(2370 pounds NAPl-IC One Rotary Drum Filter per hour of cotton cloth,total capacity (483.3 square feet of surface of NAPI and NAP2) area) collecting from NAP 1. 11 nappers total. 8 napping black _ fabric and 3 not operating. Filter One Rotary Drum Filter _ NAP2 collects particulate and it drops out NAP2-lC (142.1 square feet of surface into building below filter. Waste area)collecting from NAP 2. material is collected and sold to another company. RP Retention pond N/A N/A Operating. VE= 0%:No offsite odor. Insignificant Sources: The facility has three insignificant/exempt sources: two steam heated spasher dryers (I-SDI 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 19 June 2014,I,Maureen Conner, of the Fayetteville Regional Office, met with Mr. David Bruton to conduct and annual compliance inspection.Mr.Bruton checked FacFinder and found no mistakes. (Google maps and GPS systems locate Wade Manufacturing at 76 Mill Road, a correct address but not in our system.)Mr. Bruton stated there had been no additions since the last inspection.However, some of their permitted equipment is not operational or has been removed,which Mr. Bruton noted on the emission source list and pointed out during the facility tour. 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. _ The facility had the current permit on site.Mr. Bruton provided all applicable records for review. Oil sulfur content,emissions,HAP emissions and PSD avoidance records were checked and well organized. The fuel oil certifications indicated sulfur content 1.61%the last several times it was purchased.The last purchase of No.6 fuel oil was 3 January 2011.The VOC emissions,HAP emissions, and SOz emissions appeared in compliance with the air permit.The facility inspects cyclones, rotary drum filter and bag filters on a monthly basis. Page 6 of 12 Visible emissions observed daily by Mr. Bruton and logs appeared to be in compliance,but there is a new requirement in their permit to re-establish normal for all their VE sources except the boilers.This was required to be completed by 7 March 2014.The facility is complying with the requirement by taking picture of the stacks at"normal' operation. As of the inspection, only a couple of the sources had pictures to re-establish"normal'and the pictures were taken not using Method 9 observation requirements.An NOD was issued to the facility on 20 June 2014 and a response is due 7 July 2014. Prior to entering the facility,the inspector checked opacity of all stacks that could be seen from the hillside to the west of the plant. I observed 5-10% visible emissions from all the facilities stacks. In the past the facility has had issues with VE, when not operating the tenter frame properly. 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,B2) 1. 15A NCAC 2D.0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS-Emissions of particulate matter from the combustion of natural gas or No. 6 fuel oil,that are discharged from these sources (ID Nos.Bl,B2) into the atmosphere shall not exceed (i) 0.33 lb/mm Btu heat input from boiler B 1 and(ii)0.47 lb/mm Btu heat input from boiler B2.No reporting/monitoring/recordkeeping. APPEARED IN COMPLIANCE—The AP-42 PM emission factors for No. 6 oil with sulfur content of 2.1% is 0.16lbs/mm BTU and natural gas is 0.007 lbs/mm BTU. The fuel oil certifications indicated sulfur content of 1.6°lo, last purchased in 3 January 2011. Facility was combusting natural gas on the day of the inspection. BI was operating but B2 was not. 2. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES- Emissions of sulfur dioxide from these sources(ID Nos.Bl,B2)shall not exceed 2.3 pounds per million Btu heat input.The S02 content of No. 6 fuel oil received and burned<2.1 %by weight. Maintain fuel oil certificates. Submit a summary report of the fuel oil supplier certifications semi- annually.No reporting/monitoring/recordkeeping for S02 emissions from natural gas. APPEARED IN COMPLIANCE: The AP-42 S02 emission factor for No. 6 oil with sulfur content of 2.1% is 2.Ilbs/mm BTU and natural gas is 0.005 lbs/mm BTU. The fuel oil certifications indicated less than 2.1%at 1.61%. Facility was combusting NG on the day of the inspection. BI was operating but B2 was not. Semi-annual report turned in on time and appeared in compliance. 3. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS -Visible emissions from these sources (ID Nos.Bt,112) shall not be more than 20 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. 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 from this BI,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. Page 7 of 12 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.B1,132) 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. Semi-annual summary report. APPEARED IN COMPLIANCE: Records indicated S02 emissions less than 250 tons.As of May 2014, -3 TPY. The facility calculates monthly S02 emissions and records that in the logbook. Semi-annual reports received on time, indicate compliance. Emission Source B2 is not in operation. 5. 15A NCAC 2Q.0317: AVOIDANCE CONDITIONS (Avoidance of 40 CFR Part 63 Subpart JJJJJJ)40 CFR 63, Subpart JJJJJJ, "National Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial, Commercial, and Institutional Boilers"is not applicable to the facility because the boilers (ID Nos.Bl,B2)are considered gas-fired boilers, provided(i)Gaseous-fuels are not combined with any solid fuels (ii) liquid fuel only during periods of gas curtailment, gas supply interruption, startups, or periodic testing on liquid fuel(iii)Periodic testing of liquid fuel shall not exceed a combined total of 48 hours during any calendar year.A notification submitted within 30 days of the date the fuel-switch or physical change,compliance within 180 days. 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" six times (1/22, 1/23, 1/28, 1/31, 2/11, 3/4,3/5)in 2014 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. PIGI) 1. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES -Emissions of particulate matter from these sources(ID Nos.PR3,PIG1) shall not exceed an allowable emission rate.Maintain production records such that the process rates "P" in tons per hour.No reporting. f APPEARED IN COMPLIANCE: The air permit review indicated that PM emissions are below the limits. PR3 and PlGlwere not operating during the inspection. Production records are kept onsite and emissions are calculated monthly. 2. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES - Emissions of sulfur dioxide from this source(ID No.PIGI) shall not exceed 2.3 pounds per million Btu heat input. No monitoring/recordkeeping/reporting. APPEARED IN COMPLIANCE: The AP-42 S02 emissions factor for natural gas is 0.005 lbslmm BTU. PR3 and PIGI were not operating during the inspection. 3. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-Visible emissions from these sources(ID Nos.PR3,PIG1) 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. Page 8 of 12 APPEARED NOT IN COMPLIANCE: 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. Re-established normal not completed yet, NOD issued 20 June 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.BL1 and TEN4) 1. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES -Emissions of particulate matter from these sources(ID Nos.PR4,PR5,TEN2, TEN3,TEN4,TRI,BLI) shall not exceed an allowable emission rate.Maintain production records such that the process rates "P" in tons per hour.No reporting. APPEARED IN COMPLIANCE: The air permit review indicated that PM emissions are below the limits.)Facility was combusting NG. PR4 and TRI not operating. 2. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES - Emissions of sulfur dioxide from these sources(ID Nos.PR4,PR5,TEN2,TEN3) shall not exceed 2.3 pounds per million Btu heat input No monitoring/recordkeeping/reporting. APPEARED IN COMPLIANCE: The AP-42 S02 emissions factor for natural gas is 0.005 lbs/mm BTU. Facility was combusting NG. PR4 not operating. 3. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS -Visible emissions from these sources (ID Nos.PR4,PR5,TEN2,TEN3,TEN4,TRI,BL1) shall not be more than 20 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<20% to demonstrate compliance. VE"normal"logbook. Semi-Annual summary report. APPEARED NOT IN COMPLIANCE: VE= 10%opacity from the tenter frame stacks during the inspection. Daily observation record done by Mr. Bruton. Facility was combusting NG. PR4 not operating. Semi-annual reports received on time, indicate compliance. Re-established normal not completed yet, NOD issued 20 June 2014. D. One shop lathe (ID No. SLI) with one associated cyclone(ID No.SL1C), one starch storage silo (ID No. SSI) with two associated bagfilters (ID Nos.BF1 and BF2), and one blendomat operation (ID No. OPI) with one associated paper panel filter and one associated rotary drum filter (ID Nos. OPICA and OP1CB) 1. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES-Emissions of particulate matter from these sources(ID Nos.SLI,SS1,OP1)shall not exceed an allowable emission rate.Maintain production records such that the process rates "P" in tons per hour. Sources controlled as described in source table.Monthly visual inspection of ductwork and annual internal inspection.Inspection and monitoring logbook. Semi-annual summary reporting. Page 9 of 12 APPEARED IN COMPLIANCE: The air permit review indicated that PM emissions are below the limits. Duct work in good condition. The facility inspects and cleans out cyclones and bagfilters on a monthly basis. Internal inspections done on July 4`h shut-down. SLI and SSI not operating in several years.All sources last inspected and cleaned on 5 June 2014. Semi-annual reports received on time, indicate compliance. 2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS -Visible emissions from these sources(ID Nos.SLl,SSI,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. 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<20%to demonstrate compliance. VE"normal"logbook. Semi-Annual summary report. APPEARED NOT IN COMPLIANCE: Daily observation record 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 SS1 not operating in several years. Re-established normal not completed yet, NOD issued 20 June 2014. E. One carding and drawing operation (ID No. ACl/CARDI)with one associated rotary drum filter (ID No. CARD14C),one spinning operation(ID No. AC2) with one associated paper filter (ID No. AC24C), one weaving operation (ID Nos. AC3, AC4, _ and AC5)with one associated paper filter and two rotary drum filters (ID Nos. AC3- 1C, AC4-1C, and AC54C),and one napping operation (ID Nos.NAPI. and NAP2) with two associated rotary drum filters (ID Nos. NAP14C and NAP2-1C) 1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES -Emissions of particulate matter from these sources (ID Nos.ACl/CARDI,AC2 through AC5,NAPI,NAP2) shall not exceed an allowable emission rate.Maintain production records such that the process rates "P" in tons per hour. Sources controlled as described in source table. Monthly visual inspection of ductwork and annual internal inspection.Inspection and monitoring logbook. Semi-annual summary reporting. APPEARED IN COMPLIANCE: The air permit review indicated that PM emissions are below the limits. Duct work in good condition. 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 5 June 2014. Internal inspections done on July 4`h shut-down. Semi-annual reports received on time, indicate compliance. The weaving operation and associated starch silo have been removed. The weaving operations(ID No. AC3 and AC5)were not operated for the last 4 years. 2. 15A NCAC 2D 40521: 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.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<20% to demonstrate compliance. VE"normal" logbook. Semi-Annual summary report. Page 10 of 12 APPEARED NOT IN COMPLIANCE: No visible emissions observed during the inspection. Daily observation/record done by Mr. Bruton. Recorded observations indicate compliance. Semi-annual reports received on time, indicate compliance. The weaving operations(ID No.AC3 and AC5) were not operated for the last 4 years. Re-established normal not completed yet, NOD issued 20 June 2014. 2.2- Multiple Emission Source(s) Specific Limitations and Conditions A. One natural gas-fired textile roller printer(I ) No. PR3),one natural gas-fired pigment range (II)No. PIG1), 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 (II)Nos.BLI and TEN4),and one steam heated cotton dye range (ID No. CR1) 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 with saran wrap. No solvent rags or open(operational)parts washers were noted. Mr. Bruton stated that this regulation requires continual oversight to ensure compliance.Monitoring records are complete and indicate compliance. Last inspection completed 22 May 2014. 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.PIG1),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. TRI), and one bleach range and natural gas-fired finishing range (ID Nos.BL1 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, TRI,BLI)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. VOC emissions as of May 2013 was 1.91 TPY. The highest month in the last 12 months was in March 2014 with 0.45 TPY. Semi-annual reports received on time, indicate compliance. Emission sources PR3, PR4 and TR1 are not in operation. C. All emission sources State-enforceable Only 1. 15A NCAC 2D.1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS -The Pennittee shall not operate the facility without implementing management practices or installing and Page 11 of 12 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 IN COMPLIANCE: 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 .1100 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 perhour Tenter frame(ID No.TEN4) Ammonia 0.004 pounds per hour Boiler(ID No.131) 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 St rene 1.24 pounds per hour Pigment range(ID No.PIG1) Formaldehyde 0.0008 pounds per hour Thermosol range(ID No. TR1) Ammonia 1.12 pounds per hour Formaldehyde 0.002 pounds perhour Retention pond(ID No.RP) Ammonia 0.0012 pounds per hour Formaldehyde 0.0016 pounds 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. Page 12 of 12 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 of production, and the maximum hourly rate of formaldehyde input to each tender frame (ID Nos. TEN2, and TENS)for each day of production. Mr. Bruton keeps records for each day. The maximum hourly emissions are calculated by dividing the daily usage of chemicals by the total hours of operation. 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 12 months for(PR3) = 2.85 lb/hr and for(PR4&PR5) = 1.408 lb/hr. Formaldehyde highest emission rate for the last 12 months for(TENS) =0.0572 lb/hr and for(TEN2) = 0.0604 lb/hr. Emission Sources PR3 and PR4 were not operating. Quarterly reporting was submitted on time and appeared to be in compliance. 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). 10-YEAR COMPLIANCE HISTORY: 9 May 2013-CAI VE Monitoring and Record Keeping 9 Nov 2012-NOV for VE>20% — 5 Oct 2007 -NOV/NRE issued for exceeding VE limit(1D No.TEN4) 23 Sep 2003—NOV/NRE issued for exceeding VE limit(B 1 and T4)—CPA for$8,000 19 Sep 2002—NOV issued for late submittal of TV permit application for renewal. 17 May 2002—Warning Letter regarding Annual Compliance Certification COMMENTS AND RECOMMENDATIONS: Based on the observations made during the 20 June 2014 inspection,Wade Manufacturing appeared to be not operating in compliance with all regulations outlined in their current air permit. NOD issued 20 June 2014 for 2D .0521 —Visible Emissions for failure to re-establish"normal"VE for emission sources by 7 March 2014. /MDC