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HomeMy WebLinkAboutAQ_F_0400016_20130501_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office _ AIR QUALITY Wade Manufacturing Cc -Wadesboro NC Facility ID 0400016 Inspection Report County/FIPS:Anson/007 Date: 05/08/2013 Facility Data Compliance Data Wade Manufacturing Co-Wadesboro Inspection Date 05/01/2013 Highway 74 East Inspector's Name Maureen Matroni-Rakes Wadesboro,NC 28170 Operating Status Operating Lat: 34d 57.8720m Long: 80d 2.6476m Compliance Code Compliance-inspection SIC: 2261/Finishing Plants,Cotton Action Code FCE NAICS: 313311 /Broadwoven Fabric Finishing Mills On-Site Inspection Result Compliance Contact Data Permit Data Facility Contact Authorized Contact Technical Contact Permit 03577/T16 David Bruton Bernard Hodges David Bruton Issued 5/27/2008 Plant IE President Plant IE Expires 4/30/2013 (704)694-2131 (704)694-2131 (704)694-2131 Classification Title V Permit Status Active Inspector's Signature: M Comments: �� �/P " .� Date of Signature: MACT/GACT:The facility has two boilers(B1 &B2)both are subject to GACT 6J -Condition#1 — Liquid Fuel OR Biomass>=10 MMbtu/hr(Existing Sources).The boilers have combusted only natural gas for several years now but have the capability to run No. 6. Initial Notice completed. 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 fabric.The process involves looming/spinning raw cotton into yarn, slashing, weaving and twisting of yarn,bleaching, dying,printing, and finishing of cloth. 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. 03577T16, issued 27 May 2008, with an expiration date of 30 April 2013. Employees: 150 Hours: 4 or 5 days a week,7am-4 pm. Page 2 of 10 EmMsron ; Control Source Emission Source Control Device " Device Description Description ID ATo ,. . . ID No: B 1 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. PRl One steam heated textile roller printer N/A N/A (3,600 pounds of cloth per hour process capacity)consisting of: a) 10 print stations b) 1 steam heated dryer Not operable. Power pulled from the equipment. 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. PR6 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. Power pulled from the equipment. 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. Page 3 of 10 m>asion �' Control n Emission source. Control Device ` Descri hon Device Description s�ID NR. P 1D No. 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 43 yards/minute. Printing 5 colors(able to do up to 12)of blue and green on cotton to make kitchen fabric. VE501b. TENT 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 8.5 million Btu per hour three zone tenter frame oven Not capable of operating. Power pulled. 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 61 yards/minute. VE 5%. Finishing Carolina blue poly-cotton blend. Temperature 369-373 °F. 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 70 yards/minute. VE 10%. Finishing grey cotton. Temperature 372-383 °F. Set point 385°F. J-BOX,BLl, One bleach range and one natural gas- N/A N/A and TEN4 fired 8.5 million Btu per hour three zone finishing range Operating at 67 yards/minute. VE 10%. Finishing grey cotton flannel. Temperature 375°F. Set point 385°F. Page 4 of 10 Emission"' 'Control Emission Source Control Device = Srturce „' Device .Y1 Nay, DQscript►on ID No. ," 'DeseriptFou CRl Steam heated cotton dye range N/A N/A Operating at 67 yards/minute.Dying black poly-cotton blend. VE 5%. PIGI One pigment range(4,800 pounds of N/A N/A cloth per hour process capacity) consisting of: _ a) 1 natural gas-fired 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) 1 natural gas-fired 7.0 million Btu per hour dryer Not operating during inspection. 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. SS1 One starch storage silo (22.5 tons per BF 1 One Bagfilter(12 square feet hour filling rate) of filter area) in parallel with Empty and has not been used in years BF 2 One Bagfilter(12 square feet but still at facility. 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) in series with Operating. Paperfilters automatically OP 1CB One Rotary Drum Filter(46.5 roll to expose new filter when pressure square feet of filter area) drop gets close to 1.25". Blendomat will shut off when a paper filter roll needs to be replaced. Rolls are checked daily. ACl/CARDI One carding and drawing operation CARDl-IC One Rotary Drum Filter (2100 pounds per hour of cotton fiber) (545.3 square feet of surface area) Operating.Drum filter collects all particulate and drops out indoors. Wade collects this waste and sells it. Page 5 of 10 Emu sion : ,>ID_� Emission Source Centra)( " Control Device _ „Source ; Devic'e D6scrigtlon . No. . Description 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 paperfilter roll needs to be replaced. Rolls are checked daily. AC3 One weaving operation(1870 pounds AC34C One Paper Filter(371.2 per hour of cotton yarn), square feet of surface area) consisting of: collecting from AC-3. three weaving areas AC3,AC4,and AC4 AC5 AC44C One Rotary Drum Filter (834.9 square feet of surface AC3and AC5's power has been cut area)collecting AC-4. and do not operate.AC4 was operating in the weaving area. 10 One Rotary Drum Filter AC5 paper filters.Air is then recycled into AC5-IC (545.3 square feet of surface the indoor air supply. VE=O%. area)collecting AC-5. NAPI One napping operation(2370 pounds NAPl-lC One Rotary Drum Filter per hour of cotton cloth),consisting of: (483.3 square feet of surface two napping areas NAPI and NAP2 area)collecting from NAP 1. 11 nappers total. 5 napping white One Rotary Drum Filter NAP2 fabric, 3 napping golden yellow fabric NAP24C (142.1 square feet of surface and 3 not operating. Filter collects area)collecting from NAP 2. particulate and it drops out into building below filter Waste 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-SD1 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 1 May 2013 I,Maureen Matroni-Rakes, 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.The facility has a renewal application in with Page 6 of 10 RCO currently.Their current permit has an expiration date of 30 April 2013 but will be active until they receive their new permit. NOTE:MT.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. In November 2012 at approx 8:30AM Robert Hayden observed VE 6 minute averages of 66%, 66%, 65%. It was found that TEN2 was running at too high of temperature and the temperature was turned down. Subsequently an NOV was issued to the facility to determine what went wrong and for them to come up with a plan to avoid VE issues in the future.DAQ determined that we would follow-up during the next compliance inspection. During the inspection VE logs for the day in question made no note of VE concerns from DAQ,NOV for the VE nor that the VE was above normal. A CAI letter will be sent to the facility to ensure that VE observations are being done correctly and VE logbooks are complete and accurate. 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 S02 emissions appeared in compliance with the air permit. Visible emissions observed daily by Mr. Bruton and logs appeared to be in compliance.The facility inspects cyclones, rotary drum filter and bag filters on a monthly basis. 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.The inspector 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 A. 15A NCAC 213.0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS- (boiler ED No.Bl),PM shall not exceed 0.33 pounds per million Btu heat input. [15A NCAC 2D.0503 (a)] APPEARED IN COMPLIANCE—The AP-42 emission factors for No. 6 oil with sulfur content of 2.1%is 0.16 lbs/mmBTU and natural gas is 0.007 lbs/mmBTU The fuel oil certifications indicated sulfur content of 1.6%, last purchased in January 2011. Facility was combusting natural gas on the day of the inspection. B. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES-Natural gas/No. 6 fuel oil-fired boiler(ID No.Bl) -This is the main boiler,which operates primarily on natural gas. It was installed in 1985 (so NSPS Subpart Dc does not apply)and has a maximum heat input capacity of 72 mmBtu/hr.S02 shall not exceed 2.3 pounds per million Btu heat input. The maximum sulfur content of any oil received and burned in the boiler shall not exceed 2.1 percent by weight APPEARED IN COMPLIANCE: The AP-42 emission factor for No. 6 oil with sulfur content of 2.1%is 2.1lbs/mmBTU and natural gas is 0.005 lbs/mmBTU. The fuel oil certifications indicated less than 2.1%at 1.61%. Facility was combusting NG on the day of the inspection. Semi-annual reports received on time, indicate compliance. Semi-annual report turned in on time and appeared in compliance. C. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-Natural gas/No. 6 fuel oil-fired boiler (ID No.Bl)Visible emissions from this source shall not be more than 20%opacity.Daily observations done by Normal/not normal scale. Page 7 of 10 APPEARED IN COMPLIANCE: No visible emissions observed during the inspection from this boiler. Logbook indicated daily VE observation recorded and indicated compliance. Facility was combusting NG. Semi-annual reports received on time, indicate compliance. Semi-annual report turned in on time and appeared in compliance. D. 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 (boiler ID No.B2),are discharged from this source into the atmosphere shall not exceed 0.47 pounds per million Btu heat input. APPEARED IN COMPLIANCE: B2 is not operational and would require several new parts to run. E. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES-Natural gas/No.6 fuel oil-fired boiler(ID No.B2)-This is the main boiler,which operates primarily on natural gas. It was installed in 1985 (so NSPS Subpart Dc does not apply)and has a maximum heat input capacity of 72 mmBtu/hr. S02 shall not exceed 2.3 pounds per million Btu heat input. The maximum sulfur content of any oil received and burned in the boiler shall not exceed 2.1 percent by weight. APPEARED IN COMPLIANCE:B2 is not operational and would require several new parts to run. Semi- annual report turned in on time and appeared in compliance. F.15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-Natural gas/No.6 fuel oil-fired boiler (ID No.112)Visible emissions from this source shall not be more than 40%opacity.Daily Observation based on Normal/not normal. Semi-Annual Report. APPEARED IN COMPLIANCE:B2 is not operational and would require several new parts to run. Semi- annual report turned in on time and appeared in compliance. G. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES- One natural gas-fired textile roller printer(ID No.PR3) and one natural gas-fired pigment range (ID No. PIG1),and one natural gas-fired textile roller printer(ID No.PRI).Emissions of particulate matter from these sources shall not exceed an allowable emission rate.Maintain production records for emission calculation. APPEARED IN COMPLIANCE: The air permit review indicated that PM emissions are below the limits. PR3 and PRI processes were not operating during the inspection. PIGl was operational and combusting NG. Production records are kept onsite and emissions are calculated monthly. H. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES-One natural gas-fired textile roller printer(ID No.PR3)and one natural gas-fired pigment range (ID No.PIG1). Emissions of sulfur dioxide from these sources shall not exceed 2.3 pounds per million Btu heat input. APPEARED IN COMPLIANCE: The AP-42 emissions factor for No. 6 oil with sulfur content of 2.1%is _ 2.1 lbs/mmBTU and natural gas is 0.005 lbs/mmBTU The fuel oil certifications indicated 1.6%. (Emission source PR3 was not operational)Facility was combusting NG on the day of the inspection. I. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS- One natural gas-fired textile roller printer (ID No.PR3)and one natural gas-fired pigment range (ID No.PIGI),and one natural gas-fired textile roller printer(ID No.PRI).Visible emissions from these sources shall not be more than 40 percent opacity, observe daily and report twice a year. - APPEARED IN COMPLIANCE: PR3 and PR1 processes were not operating during the inspection. PIGlwas operational and VE was <20%. Daily observation record done by Mr.Bruton. Recorded observations indicate compliance. Semi-annual reports received on time, indicate compliance. Facility was combusting NG on the day of the inspection. Page S of 10 K. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES- _ _ One natural gas-fired textile roller printer(ID No.PR6),two natural gas-fired textile screen printers(ID Nos.PR 4 and PR 5),three natural gas-fired tenter frames(ID Nos.TEN I,TEN2,and TEN3),one natural gas-fired thermosol range(ID No.TRl),and one bleaching range with tenter frame(ID Nos. J-BOX,BLl, and TEN4).Emissions of particulate matter from these sources shall not exceed an allowable emission rate APPEARED IN COMPLIANCE: The air permit review indicated that PM emissions are below the limits. (Emission sources PR6, PR4, TRI and TEN]are not operational)Facility was combusting NG. L.15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-One natural gas-fired textile roller printer (ID No.PR6),two natural gas-fired textile screen printers(ID Nos.PR 4 and PR 5),three natural gas-fired tenter frames(ID Nos.TEN I,TEN2,and TEN3),one natural gas-fired thermosol range(ID No.TRI),and one bleaching range with tenter frame(ID Nos. J-BOX,BLl,and TEN4—20010 opacity).Visible emissions from these sources shall not be more than 20 percent opacity,observe daily and report twice a year. APPEARED IN COMPLIANCE: There appeared approximately 10%opacity from the tenter frame stacks - - during the inspection.Daily observation record done by Mr. Bruton. Semi-annual reports received on time, indicate compliance. (Emission sources PR6, PR4, TRI and TEN]are not operational) In November 2012 at approx 8:30AM Robert Hayden observed VE 6 minute averages of 6601o, 66%a, 65010. It was found that TEN2 was running at too high of temperature and the temperature was turned down. Subsequently an NOV was issued to the facility to determine what went wrong and for them to come up with a plan to avoid VE issues in the future. DAQ determined that we would follow-up during the next compliance inspection.During the inspection VE logs for the day in question made no note of VE concerns from DAQ,NOV for the VE nor that the VE was above normal.A CAI letter will be sent to the facility to ensure that VE observations are being done correctly and VE logbooks are complete and accurate. M. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES-One natural gas-fired textile roller printer(ID No.PR6),two natural gas-fired textile screen printers(ID Nos. PR 4 and PR 5),three natural gas-fired tenter frames(ID Nos.TENI,TEN2,and TEN3),one natural gas- fired thermosol range(ID No.TRl),and one bleaching range with tenter frame(ID Nos. J-BOX,BLI,and TEN4). Emissions of S02 from these sources shall not exceed 2.3 pounds per million Btu heat input. APPEARED IN COMPLIANCE: The AP-42 emissions factor for No. 6 oil with sulfur content of 2.1%is 2.1 lbs/mmBTU and natural gas is 0.005 lbs/mmBTU. The fuel oil certifications indicated 1.6% sulfure. (Emission sources PR6, PR4, TRI and TEN] are not operational)Facility was combusting NG. N. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES- One shop lathe(ID No. SLl)with one associated cyclone(ID No.SL1C),one starch storage silo(ID No. SS 1)with two associated bagfilters(ID Nos.BFl and BF2),and one blendomat operation(ID No. OPl) with one associated paper panel filter and one associated rotary drum filter(ID Nos. OP1CA and OP1CB). Emissions of particulate matter from these sources shall not exceed an allowable emission rate. Use control device equiptment when operating emission sources.I&M:monthly external inspection of the control _ devices and ductwork/semi-annual internal inspection of the control devices to ensure structural integrity. Report of monitoring and recordkeeping activities in a log book. APPEARED IN COMPLIANCE: The air permit review indicated that PM emissions are below the limits. Duct work in good condition. The facility inspects cyclones and bagfilters on a monthly basis. Last checked on 15 April 2013. Semi-annual reports received on time, indicate compliance. O. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-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. OPl)with one associated paper panel filter and one associated rotary drum filter( ID Nos. OP1CA and OPICB).Visible emissions from these sources shall not be more than 20 percent opacity,observe daily and report twice a year. Page 9 of 10 APPEARED IN COMPLIANCE: Daily observationlrecord done by Mr. Bruton. Recorded observations indicate compliance.Semi-annual reports received on time, indicate compliance. VE=0%. P. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES- One carding and drawing operation(ID No.ACl/CARDl)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.AC34C,AC44C,and AC5-1C),and one napping operation(ID Nos.NAPI and NAP2) with two associated rotary drum filters(ID Nos.NAPI-IC and NAP24C).Emissions of particulate matter from these sources shall not exceed an allowable emission rate. Use control devices when operating emission sources and I&M:monthly external inspection of the control devices and ductwork/semi-annual internal inspection of the control devices to ensure structural integrity and maintain logbook. 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 15 April 2013. Internal inspections done on July 4" 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. Q.15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-One carding and drawing operation(ID No.AC1/CARDI) with one associated rotary drum filter(ID No.CARDI-1C),one spinning operation(ID No.AC2)with one associated paper filter(ID No.AC2-1C),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 AC5- IQ,and one napping operation(ID Nos.NAP and NAP2)with two associated rotary drum filters(ID Nos. NAP14C and NAP24C). Visible emissions from these sources shall not be more than 40 percent opacity, observe daily and report twice a year. 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. (Emission Sources AC3 and AC5 and associated control devices are not operational) R.Multiple Emission Source(s)Specific Limitations and Conditions 1. 2D.0958,VOC work practice standards-Generally refers to dye vats,parts washers in the maintenance area and solvent-laden rags. Monthly observations of the printing,finishing,bleaching,can range,cotton dye range and thermosol range are made. 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. Semi-annual report submitted on time and appeared in compliance. 2. 2D.1100 Toxics(ammonia,formaldehyde) emission limitation/logbook/reporting: i. The input rate of ammonia to each roller printer(ID Nos.PRl,PR3, &PR6) shall not exceed 3.35 lb/hr. ii. The input rate of ammonia to each screen printer(ID Nos.PR4&PR5)shall not exceed 2.85 lb/hr. iii. The input rate of formaldehyde to each tenter frame(ID Nos.TEN I &TEN3)<0.104 lb/hr. iv. The input rate of formaldehyde to the tenter frame(ID No.TEN2)shall not exceed 0.126 lb/hr. APPEARED IN COMPLIANCE: Records showed no exceedance for all limits. Records are maintained for the maximum hourly rate of ammonia input to each printer(ID Nos. PRI, PR3, PR4, PR5, and PR6)for each day of production, and the maximum hourly rate of formaldehyde input to each tenderframe(ID Nos. TENT, TEN2, and TEN3)for each day of production. Mr. Bruton keeps records for each day. The Page 10 of 10 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. (Emission Sources PRI, PR3, PR4, and TENI are not operational)Ammonia highest emission rate for the last 12 months for(PRI, PR3 &PR6) = 1.024lb/hr on 41112013 and for(PR4&PR5) = 1.20 lbAr. Formaldehyde highest emission rate for the last 12 months for(TENI &TEN3) =0.0932 lb/hr on 313112013 and for(TEN2) = 0.0694 lb/hr on 41212013. 3.Odorous Emissions—2D.1806 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. 4. AVOIDANCE FOR 15A NCAC 2D.0530:PREVENTION OF SIGNIFICANT DETERIORATION-Two natural gas/No. 6 fuel oil-fired boilers (ID Nos.B1 and 132). S02 emissions shall be less than 250 tons per consecutive twelve months period. Submit a summary report of monitoring and recordkeeping activities twice a year. Calculate monthly S02 emissions. APPEARED IN COMPLIANCE: Records indicated S02 emissions less than 250 tons.As of March 2013 2.59 TPY. The highest ton/month is the last 12 months is 0.65 tons/month back in May 2012. 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.AVOIDANCE FOR 15A NCAC 2D.0530:PREVENTION OF SIGNIFICANT DETERIORATION-one steam heated textile roller printer(ID No.PRI);one natural gas-fired textile roller printer(ID No.PR3),one natural gas-fired pigment range(ID No.PIGI),one natural gas-fired textile roller printer(ID No.PR6),two natural gas-fired textile screen printers(ID Nos.PR4 and PR5),three natural gas-fired tenter frames(ID Nos.TEN I,TEN2,and TEN3),one natural gas-fired thermosol range (ID No.TRI),and one bleach range and natural gas-fired finishing range(ID Nos.J-BOX,BLI,and TEN4).VOC emissions shall be less than 250 tons per consecutive twelve months period. Submit a summary report of monitoring and recordkeeping activities twice a year.Calculate monthly VOC emissions. 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 2012 was 2.23 tons/year. The highest 12 month was in March 2013 with 2.59 tons/year.Semi-annual reports received on time, indicate compliance. (Emission sources PR1, PR3, PR6, PR4, TEN] and TR1 are not in operation) 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 Nov 2013 —NOV for VE>20% 5 Oct 2007 -NOV/NRE issued for exceeding VE limit(ID No.TEN4) 23 Sep 2003—NOV/NRE issued for exceeding VE limit(B1 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 1 May 2013 inspection,Wade Manufacturing appeared to be _ operating in compliance with all regulations outlined in their current air permit but there are concerns with how the VE records are being kept and how &when the VE observations are being made. Recommend issuing CAI to ensure better recordkeeping and monitoring of VE logbooks. MDR