AQ_F_0400016_20130510_CMPL_RFI

k
I
A042 A
NCDENR
iNorth Carolina Department of Environment and Natural Resources
Division of Air Quality
Pat McCrory Sheila C. Holman John E. Skvarla, III
Governor Director Secretary
10 May 2013
Mr. Bernard Hodges, President
Wade Manufacturing Company
P.O. Box 32
Wadesboro,NC 28170
SUBJECT: Compliance Additional Information: Monitoring and Recordkeeping Concerns
Wade Manufacturing Company
Wadesboro, Anson County Fee Category: Title V
Facility ID: 06/0400016 Permit No. 03577T16
Dear Mr. Hodges,
On 1 May 2013, Ms. Maureen Matroni-Rakes of the Fayetteville Regional Office, DAQ,
conducted a compliance inspection of your facility in Wadesboro, Anson County,North
Carolina. In the past decade we have had concerns about the visible emissions (VE) from
several sources at your plant. On 7 November 2012, Robert Hayden of this office observed
excessive VE from tenter frame 2 (TEN2) at your facility with opacity exceeding 60%. Mr.
Hayden spoke with Mr. David Bruton, who acknowledged the excessive smoke and later stated it
was caused by an incorrect temperature setting. As a result, a Notice of Violation(NOV) was
issued to your facility on 9 November 2013 for violating 15A NCAC 2D .0521 "Control of
_ Visible Emissions." We received your response letter dated 16 November 2012 which also
contained the operational data for this tenter frame.
Ms. Matroni-Rakes met with David Bruton, Facilities Manager, for the compliance
inspection on 1 May 2013. She reviewed the records of VE observations for the last 6 months
and noted that there was no mention of VE issues and corrective actions on 7 November 2013.
According to your response to the NOV, the plant began production at 7:05 AM on 7 November
2012, and the records show Mr. Bruton's VE observation was at 7:12 AM. VE evaluations are
more appropriate when your facility is at full production rather than 7 minutes after start-up. In
addition, when we look at the data for this day, the observations were not consistent with the
evaluations made during the other operational days of the last quarter of 2012.
This office has concerns with our observations of excessive visible emissions over the
years. The purpose of the daily evaluation is to observe the sources during their routine
operation and to make sure the emissions are within a normal range. The method in the current
permit avoids sophisticated and expensive monitoring devices by allowing a subjective
Fayetteville Regional Office-Division of Air Quality
225 Green Street,Suite 714,Fayetteville,North Carolina 28301-5095
Main Phone: [phone]\DAQ Fax:[phone] \ Internet: http://wvvw.ncair.org
An Equal Opportunity 1 Affirmative Action Employer—Made in part by Recycled Paper

I
F
Mr. Bernard Hodges
i CAI-Monitoring and Recordkeeping Concerns
10 May 2013
Page 2 of 2
evaluation based on how the emissions appear when the systems are operated correctly
("normal"). To be valid, this system must be followed conscientiously, with valid observations
and accurate record keeping.
Please respond to this information request in writing as soon as possible, but not
later than 31 May 2013. In your response, please describe actions you will take to ensure that
the visible emissions from your facility do not exceed allowable/normal opacity. The plan
should describe when observations are to be made [emission sources fully operating], from
where [sun at your back] and by whom, a description of"normal" for each stack, actions to be
taken if exceedences are observed, and the record of all related activities. The written log itself
should include a description(and/or photo) of normal emissions, and columns with the date and
time of observation, the observer's name or initials, operational status of the source, the opacity
determination(normal or excessive) and the remedial actions, if excessive emissions are noted.
The form should be self-explanatory for anyone tasked to do the observations, especially for the
days on which Mr. Bruton is not available. Over the years, Mr. Burton has stated his desire to
summarize these records electronically for reporting purposes. Many companies do this, but
they also are able to provide written records as described above that support the electronic
summary.
We have also noted that facilities with the potential for excess emissions are very
successful in controlling these emissions when all employees who see the stacks are aware of the
standard, and know to notify the appropriate person if an exceedence is suspected,
Please be advised that neither this letter, nor any subsequent action, absolves you from
responsibility for any violation or damage to public or private property or from any enforcement
action available to this agency.
p If you have any questions regarding this matter, please call Maureen Matroni-Rakes,
kEnvironmental Engineer, Robert Hayden, Compliance Coordinator, or me at 910-433-3300.
Sr cere ,
F
VI � , .
Steven F. Vozzo
Regional Air Quality Supervisor
Fayetteville Regional Office
SFV\mdr
cc: FRO Facility Files