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HomeMy WebLinkAboutAQ_F_0400016_20110316_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: 24 March 2011 Facility Data Compliance Data Wade Manufacturing Co -Wadesboro Inspection Date 03/16/2011 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: Comments: Date of Signature: 7+ �at�Ci� 2�1 i MACT/GACT: This facility is not subject to any MACTs or GACTs at this time. 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. 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-4pm. PERMITTED EMISSION SOURCES: At the time of the inspection,Wade Manufacturing was operating under Permit No.03577T16 which includes the following emission sources: P B I One natural gas/No. 6 fuel oil-fired N/A N/A boiler(72 million Btu per hour heat input capacity) One natural gas/No. 6 fuel oil-fired N/A N/A B2 boiler(24.76 million Btu per hour heat input) PRI 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 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) 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) I natural gas-fired dryer(2 million Btu per hour heat input) 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 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 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 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) I natural gas-fired 12.0 million Btu per hour eight zone tenter frame oven 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) I natural gas-fired 6.0 million Btu per hour two zone tenter frame oven J-BOX,BLI, One bleach range and one natural gas- N/A N/A and TEN4 fired 8.5 million Btu per hour three zone finishing range CRI Steam heated cotton dye range N/A N/A 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) I pad applied ink dyeing station c) I steam heated dryer TRI 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 SLI One shop lathe(500 pounds per hour SL 1C One Cyclone(15 inch of rubber covered pad rolls) diameter) SSI One starch storage silo(22.5 tons per BF I One Bagfilter(12 square feet hour filling rate) of filter area) in parallel with BF 2 One Bagfilter(12 square feet of filter area) OPI 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 OP ICB One Rotary Drum Filter(46.5 square feet of filter area) AC1/CARDI One carding and drawing operation CARDI-IC One Rotary Drum Filter (2100 pounds per hour of cotton fiber) (545.3 square feet of surface area) AC2 One spinning operation(2100 pounds AC2-IC One Paper Filter(266.8 per hour of cotton fiber) square feet of surface area COMPLIANCE INSPECTION SUMMARY: On 13 April 2010,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. Good thing to know is that Mr. Bruton normally takes lunch from 1 lam to Noon,so plan the inspection accordingly. Table 1- Non-Operational and Removed Permitted Sources NotOpeatlgnal Re_h7ditli4m* actlfty B2 TEN (mostly removed,only frame left) PR1 PR6 SS1 TR1 AC3 AC5 M PR3 rarely used but still operational. 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 21 December 2010.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 incompliance.Mr. Bruton observes VE every day at 9:45am when the plant is at full operation but professes to be unable to determine 20%opacity.He determines normal by comparing VE to previous days. Mr.Bruton's daily VEE log indicated`normal'every workday for the last several years.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 no visible emissions from the boiler stacks. A. 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.Ill),that are discharged from this source into the atmosphere shall not exceed 0.33 pounds per million Btu heat input. [15A NCAC 2D.0503 (a)] 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 0.007lbsvinmBTU The fuel oil certifications indicated sulfur content less than 2.1%. B. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES-Natural gas/No. 6 fuel oil-fired boiler(ID No.B1)-This is the main boiler,which operates primarily on natural gas. It was installed in 1985 (so NSPS Subpart De does not apply) and has a maximum heat input capacity of 72 mmBtu/lu-. I. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes,ores, and other substances shall be included when determining compliance with this standard. 2. The maximum sulfur content of any oil received and burned in the boiler shall not exceed 2.1 percent by weight 3. The Permittee shall submit a summary report of the oil supplier certifications by January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. IN COMPLIANCE: • The AP-42 emission factor for No. 6 oil with sulfin-content of 2.1%is 2.Ilbs/mmBTU and natural gas is 0.005 lbs/mmBTU. • The fiiel oil certifications indicated less than 2.1%at around 1.61% • Semi-annual reports received on time, indicate compliance. C. I5A NCAC2D.052I: CONTROL OF VISIBLE EMISSIONS- Natural gas/No. 6 fuel oil-fired boiler (ID No. BI) 1. Visible emissions from this source shall not be more than 20%opacity 2. To assure compliance,While firing No. 6 fuel oil once a day the Permittee shall observe the emission points of this source for any visible emissions above normal. The daily observation must be made for each day of the calendar year period to ensure compliance with this requirement. 3. The Permittee shall submit a summary report of the oil supplier certifications by January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June.All instances of deviations from the requirements of this permit must be clearly identified. IN COMPLIANCE: • No visible emissions observed during the inspection from this boiler. • Logbook indicated daily VE observation recorded and indicated compliance. • Semi-annual reports received on time, indicate 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. IN COMPLIANCE: B2 is not operational and not using no No.6 or natural-gas. 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 De does not apply)and has a maximum heat input capacity of 72 mmBtu/hr. 1. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes,ores,and other substances shall be included when determining compliance with this standard. 2. The maximum sulfur content of any oil received and burned in the boiler shall not exceed 2.1 percent by weight. 3. The Permittee shall submit a summary report of the oil supplier certifications by January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. IN COMPLIANCE: B2 is not operational and not using no No.6 or natural gas. F. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS-Natural gas/No. 6 fuel oil-fired boiler (ID No.B2) 4. Visible emissions from this source shall not be more than 40%opacity 5. To assure compliance, while firing No. 6 fuel oil once a day the Permittee shall observe the emission points of this source for any visible emissions above normal. The daily observation must be made for each day of the calendar year period to ensure compliance with this requirement. 6. The Permittee shall submit a summary report of the oil supplier certifications by January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June.All instances of deviations from the requirements of this permit must be clearly identified. IN COMPLIANCE:B2 is not operational and not using no No.6 or natural gas. 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.PIG[),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 as calculated by the following equation: E=4.10 x P 0.67 Where E=allowable emission rate in pounds per hour P=process weight in tons per hour INCOMPLIANCE: The air permit review indicated that PM emissions are below the limits. PR3 and PRI processes were not operating during the inspection. PIGI was operational and using No.6 fuel oil with a 1.61%sulfur content. 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. PIGI),and One natural gas-fired textile roller printer(ID No.PRI). Emissions of sulfur dioxide from these sources shall not exceed 2.3 pounds per million Btu heat input. IN COMPLIANCE: The AP-42 emissions factor for No. 6 oil with sulfur content of 2.1%is 2.1 Ibs/mmBTU and natural gas is 0.005 lbs/mmBTU. The fuel oil certifications indicated less than 2.1%. (Emission source PRI and PR3 not operational) 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. IN COMPLIANCE: These processes were not operating during the inspection. Daily observation/record done by Mr. Bruton. Recorded observations indicate compliance. Semi-annual reports received on time, Indicate compliance. (Emission source PRI and PR3 not operational) 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.TENT,TEN2,and TEN3), one natural gas-fired thermosol range(ID No.TRI),and one bleaching range with tenter frame(ID Nos. J- BOX,BLI,and TEN4). Emissions of particulate matter from these sources shall not exceed an allowable emission rate as calculated by the following equation: E=4.10 x P 0.67 Where E=allowable emission rate in pounds per hour P=process weight in tons per hour IN COMPLIANCE: The air permit review indicated that PM emissions are below the limits. (Emission sources PR6, PR4, TRI and TENT are not operational) 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,BLI,and TEN4—20%opacity). Visible emissions from these sources shall not be more than 20 percent opacity,observe daily and report twice a year. IN COMPLIANCE: There appeared approximately 5%opacity from the tenter frame stacks daring the inspection. Daily observation/record done by Mr. Bruton. Recorded observations indicate compliance. Semi-annual reports received on time, indicate compliance. (Emission sources PR6, PR4, TRI and TENI are not operational) M. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES - One natural gas-fired textile roller printer(ID No.PR6),two natural gas-flied textile screen printers(ID Nos.PR 4 and PR 5),three natural gas-fired tenter frames(ID Nos.TEN 1,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). Emissions of sulfur dioxide from these sources shall not exceed 2.3 pounds per million Btu heat input. INCOMPLIANCE: 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 less than 2.1%. (Emission sources PR6, PR4, TRI and TEN] are not operational) N. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES-One shop lathe(ID No. SLI)with one associated cyclone(ID No.SLIC),one starch storage silo (ID No. SS 1)with two associated bagfilters(ID Nos.BFl and B172), and one blendomat operation(ID No. OPl) with one associated paper panel filter and one associated rotary drum filter(ID Nos. OPICA and OPiCB). Emissions of particulate matter from these sources shall not exceed an allowable emission rate as calculated by the following equation: E=4.10 x P 0.67 Where E=allowable emission rate in pounds per hour P=process weight in tons per hour 1. PIA Emissions: Particulate matter emissions from the shop lathe are controlled by one cyclone. Particulate matter emissions from the starch storage silo are controlled by two bagfilters. Particulate matter emissions from the blendomat operation are controlled by one paper panel filter and one rotary drum filter. 2. I&M:monthly external inspection of the control devices and duetwork/semi-annual internal inspection of the control devices to ensure structural integrity/log book 3. The Permittee shall submit the results of any maintenance performed on the control devices within 30 days of a written request by the DAQ. 4. Report of monitoring and recordkeeping activities 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. - • Semi-annual reports received on time, indicate compliance. • Emission Source SSI, SLI, SLI C BF] and BF2 not operational. O. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS- One shop lathe(ID No. SLI) with one associated cyclone(ID No. SLI C),one starch storage silo(ID No. SS 1)with two associated bagfilters (ID Nos. BFl and BF2),and one blendomat operation(ID No. Opt) with one associated paper panel filter and one associated rotary drum filter(ID Nos. OP1CA and OP1CB).Visible emissions from these sources shall not be more than 20 percent opacity,observe daily and report twice a year. 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. P. 15A NCAC 2D.0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES-One carding and drawing operation(ID No. ACl/CARD1) with one associated rotary drum filter(ID No. CARD I AQ,one spinning operation(ID No. AC2) with one associated paper filter(ID No. AC2-1 C),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. NAP I-IC and NAP2-IQ.Emissions of particulate matter from these sources shall not exceed an allowable emission rate as calculated by the following equation: E=4.10 x P 0.67 Where E=allowable emission rate in pounds per hour P,=process weight in tons per hour 1. Particulate matter emissions from the carding and drawing operation iscontrolled by one rotary drum filter. Particulate matter emissions from the spinning operation are controlled by one paper filter. Particulate matter emissions from the weaving operation are controlled by one paper panel filter and two rotary drum filters. Particulate matter emissions from the napping operation are controlled by two rotary drum filters. 2. I&M: monthly external inspection of the control devices and ductwork/semi-annual internal inspection of the control devices to ensure structural integrity/log book 3. The Permittee shall submit the results of any maintenance performed on the control devices within 30 days of a written request by the DAQ. 4. Report of monitoring and recordkeeping activities IN COMPLIANCE: • The air permit review indicated that PM emissions are below the limits. Duct work in good condition. • The facility inspects rotary drum filter and bagfilters on a monthly basis. Logs indicate I&M is done by the facility mechanic Steven Burroughs. Last checked on 14 Jan 2011 and 18 Feb 2011. Internal inspections done on July 4i'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. These sources should be removed from the permit. Q. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS- One carding and drawing operation , (ID No.ACl/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-IC),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-IQ, and one napping operation(ID Nos.NAPI and NAP2) with two associated rotary drum filters(ID Nos.NAPIAC and NAP2-1C). Visible emissions from these sources shall not be more than 40 percent opacity,observe daily and report twice a year. 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. (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 therinosol range are made. 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. 2. Toxics(ammonia,formaldehyde)emission Iimitationflogbook/reporting: i. The input rate of ammonia to each roller printer(ID Nos.PRI,PR3, and PR6)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 each tenter frame(ID Nos.TENI and TEN3) shall not exceed 0.104 pounds per hour. iv. The input rate of formaldehyde to the tenter frame(ID No.TEN2)shall not exceed 0.126 pounds per hour. 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. PR 1, PR3, PR4, PR5, and PR6)for each day of production, and the maximum hourly rate of formaldehyde input to each tender frame(ID Nos. TENI, TEN2, and TEN3)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. (Emission Sources PR1, PR3, PR4, PR6 and TENl are not operational) 3. Odorous Emissions—2D.1806 IN COMPLIANCE: No odors were detected around the facility property. 4. AVOIDANCE FOR 15A NCAC 2D.0530:PREVENTION OF SIGNIFICANT DETERIORATION-Two natural gas/No. 6 fuel oil-fired boilers (ID Nos. B 1 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. IN COMPLIANCE: Records indicated S02 emissions less that?250 torts. As of Dec 2010 2.73 totes/year. So far this year S02 is less than 0.5 tons/month in Jan and Feb 2011. 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.PIG I),one natural gas-fired textile roller printer(ID No. PR6),two natural gas-tired textile screen printers(ID Nos.PR4 and PR5),three natural gas-fired tenter frames(ID Nos.TENI,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. IN COMPLIANCE: VOC emissions are far below than 250 tons. The facility calculates monthly VOC emissions and records that in the logbook. Semi-annual reports received on time, indicate compliance. (Emission sources PRI, PR6, TENI and TRI 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: 5 Oct 07-NOV/NRE issued for exceeding VE limit(ID No.TEN4) 23 Sep 03—NOV/NRE issued for exceeding VE limit(B 1 and T4)—CPA for$8,000 19 Sep 02—NOV issued for late submittal of TV permit application for renewal. 17 May 02—Warning Letter regarding Annual Compliance Certification COMMENTS AND RECOMMENDATIONS: Based on the observations made during the 16 March 2011 inspection,Wade Manufacturing appeared to be operating in compliance with all regulations outlined in their current air permit.No suggested permit changes. MDR