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HomeMy WebLinkAboutAQ_F_0400016_20120613_CMPL_InspRpt NORTH CAROLINA DIVISION OF [[NC ayetteville Regional Office AIR QUALITY ade Manufacturing Co-Wadesboro Facility ID 0400016 Inspection Report ounty/FIPS:Anson/007 Date: 18 June 2012 Facility Data Compliance Data [[Highway ade Manufacturing Co-Wadesboro Inspection Date 06/13/2012 74 East Inspector's Name Maureen Matroni-Rakes adesboro,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 ContactFBernard ed Contact Technical Contact Permit 03577/T16 David Bruton ges David Bruton Issued 5/27/2008 Plant IE 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 jofSigmature: MACT/GACT: The facility has two boilers (B 1 &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.Tune-Up is due by 19 July 2012 and the Energy Assessment is due by 19 July 14. 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-3pm. PERMITTED EMISSION SOURCES: At the time of the inspection, Wade Manufacturing was operating under Permit No.03577T16 which includes the following emission sources: x B 1 One natural gas/No.6 fuel oil-fired boiler(72 N/A N/A million Btu per hour heat input capacity) One natural gas/No. 6 fuel oil-fired boiler(24.76 N/A N/A B2 million Btu per hour heat input) PR1 One steam heated textile roller printer (3,600 N/A N/A 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 pounds of cloth per N/A N/A 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 pounds of cloth per N/A N/A hour process capacity)consisting of: a)8 print stations b) 1 natural gas-fired dryer(2 million Btu per hour heat input) PR4 One textile screen printer (3,600 pounds of cloth per N/A N/A 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 pounds of cloth per N/A N/A 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 TEN1 One finishing range(4,320 pounds of cloth per hour N/A N/A 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 cloth per hour N/A N/A 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 TENS- One finishing range(4,320 pounds of cloth per hour N/A N/A 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, One bleach range and one natural gas-fired 8.5 N/A N/A BLl,and million Btu per hour three zone finishing range TEN4 CR1 Steam heated cotton dye range N/A N/A PIG1 One pigment range(4,800 pounds of cloth per hour N/A N/A process capacity) consisting of: a) I natural gas-fired 4.0 million Btu per hour predryer b) 1 pad applied ink dyeing station c) 1 steam heated dryer TR1 One thermasol range(4,800 pounds of cloth per hour N/A N/A process capacity) consisting of: a) 1 pad applied finishing station b) 1 natural gas-fired 7.0 million Btu per hour dryer SLl One shop lathe(500 pounds per hour of rubber SL 1C One Cyclone(15 inch diameter) covered pad rolls) SS1 One starch storage silo(22.5 tons per hour filling BF 1 One Bagfilter(12 square feet of rate) filter area) in parallel with BF 2 One Bagfilter(12 square feet of filter area OP1 One blendomat(2600 pounds per hour of cotton OP 1 CA One Paper Panel Filter(6.55 fiber) square feet of filter area) in series with OP 1CB One Rotary Drum Filter(46.5 square feet of filter area) AC1/CA One carding and drawing operation(2100 pounds CARD1- One Rotary Drum Filter(545.3 RD1 per hour of cotton fiber) 1C square feet of surface area) AC2 One spinning operation(2100 pounds per hour of AC2-IC One Paper Filter(266.8 square cotton fiber) feet of surface area COMPLIANCE INSPECTION SUMMARY: On 13 June 2012 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. NOTE: Mr. Bruton normally takes lunch from 1 lam to Noon, so plan the inspection accordingly. NOTE: Main office closed from Noon- 1PM. Call Mr.Bruton on his extension (x222)and he will let you in. This was a renewal inspection, so I discussed with Mr. Bruton the process for renewal and he stated he did not need any help and that he was having a consultant prepare the renewal. I did discuss with him removing several pieces of equipment from the permitted equipment list that were no longer in operation or had been removed due to decrease in production over the years. WE made a list of equipment which he will discuss with his boss and their consultant during the renewal. 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.Mr.Bruton observes VE every day at 9:45am when the plant is at full operation. I noted to him to mark non-operated equipment as nor running instead of noting normal emissions.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<10%visible emissions from the boiler and tenor stacks. In the past the facility has had issues with VE, when not operating the tenter frame properly. A. 15A NCAC 2D.0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS-(boiler ID No.B1),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 lbslmmBTU and natural gas is 0.007 lbslmmBTU. The fuel oil certifications indicated sulfur content of 1.6 01b, 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 De 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.Ilbs/mmBTU and natural gas is 0.005 lbslmmBTU. The fuel oil certifications indicated less than 2.1%at 1.61%. 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. APPEARED 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. Made note to Mr.Burton to note when equipment was not operating. 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.-B2)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. PIG]was operational and using No.6 fuel oil with a 1.61%sulfur content. 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) 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.PIG1),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 PRI processes were not operating during the inspection. PIGI was operational and VE was <20%. Daily observation/record done by Mr.Bruton. Recorded observations indicate compliance. Semi-annual reports received on time, indicate compliance. 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.TEN1,TEN2,and TEN3), one natural gas-fired thermosol range(ID No.TR1),and one bleaching range with tenter frame(ID Nos. J- BOX,BL1,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) 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.TEN1,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—20%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%opaciry from the tenter frame stacks during 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 TEN] 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-fired textile screen printers(ID Nos.PR 4 and PR 5),three natural gas-fired tenter frames(ID Nos.TEN1,TEN2,and TEN3),one natural gas-fired thermosol range(ID No.TRI),and one bleaching range with tenter frame(ID Nos. J-BOX,BL1, and TEN4). 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% sulfure. (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.SL1C),one starch storage silo (ID No. SS1)with two associated bagfilters(ID Nos.BF and 13172),and one blendomat operation(ID No. OP1)with one associated paper panel filter and one associated rotary drum filter(ID Nos.OP1CA and OPICB).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 16 May 2012. Semi-annual reports received on time, indicate compliance. 0. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS- One shop lathe(ID No.SL1)with one associated cyclone(ID No.SL1C),one starch storage silo(ID No. SS1)with two associated bagfilters (ID Nos.BFl and 13172),and one blendomat operation(ID No. OPI)with one associated paper panel filter and one associated rotary drum filter(ID Nos.OPICA and OPICB). Visible emissions from these sources shall not be more than 20 percent opacity,observe daily and report twice a year. APPEARED 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.AC1/CARD1) with one associated rotary drum filter(ID No. CARD 1-IQ,one spinning operation(ID No.AC2)with one associated paper filter(ID No. AC2-IQ,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 1-IC and NAP2-IQ.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 16 May 2012. 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.AC WARD 1)with one associated rotary drum filter(ID No.CARD 1-1C),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-IC,AC4-IC,and AC5-1C),and one napping operation(ID Nos.NAP and NAP2)with two associated rotary drum filters(ID Nos.NAP1-IC and NAP2-IC). 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 on 26 Jan 2012 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 &TEN3)shall not exceed 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 tender frame(ID Nos. TEN], 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 PRI, PR3,PR4, and TENT are not operational)Ammonia highest emission rate for the last 12 months for(PRI, PR3 &PR6) = 1.02 lb/hr and for(PR4&PR5) = 1.29 lb/hr. Formaldehyde highest emission rate for the last 12 months for(TEN] &TEN3) =0.061b/hr and for(TEN2) = 0.08 lb/hr. 3.Odorous Emissions—2D.1806 APPEARED IN COMPLIANCE: No odors were detected around the facility property line and 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. 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. APPEARED IN COMPLIANCE: Records indicated S02 emissions less than 250 tons.As of May 2012 <1 tons/year. The highest ton/month is the last 12 months is 0.003 tons/month back in February. 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.PRl),one natural gas-fired textile roller printer(ID No.PR3),one natural gas-fired pigment range(ID No.PIG1),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 TENS),one natural gas-fired thermosol range (ID No.TRl),and one bleach range and natural gas-fired finishing range(ID Nos.J-BOX,BL1,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 January 2012 with 2.228 tons/year. Semi-annual reports received on time, indicate compliance. (Emission sources PRI, PR3, PR6, PR4, TEN] 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 13 June 2012 inspection,Wade Manufacturing appeared to be operating in compliance with all regulations outlined in their current air permit. No suggested permit changes. RENEWAL SUGGESTIONS: -Talked with the facility about removing some of the non-operational equipment from their permit. Mr. Burton will discuss with his boss which items can be removed. MDR