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HomeMy WebLinkAboutAQ_F_1800553_20190327_CMPL_InspRpt NORTH CAROLINA DIVISION OF oresville Regional Office AIR QUALITY [[NC ll Grading&Construction Company,Inc. Facility ID 1800553 Inspection Report nty/FIPS: Catawba/035 Date: 3/27/2019 Facility Data Permit Data Neill Grading&Construction Company,Inc. Permit 09987/R02 3050 First Ave. Ct. S.E. Issued 2/18/2014 Hickory,NC 28603 Expires 1/31/2022 Lat: 35d 43.4760m Long: 81d 16.6700m Class/Status Small SIC: 1423/Crushed And Broken Granite Permit Status Active NAILS: 212313/Crushed and Broken Granite Mining and Quarrying Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Jan Wilson Ed Neill Jan Wilson MACT Part 63: Subpart ZZZZ General Manager Owner General Manager NSPS: Subpart IIII,Subpart 000 (828)324-6774 (828)324-6774 (828)324-6774 Comments: Compliance Data Inspection Date 03/27/2019 Inspector's Name Ryan Mills Inspector's Signature: (i Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: y �2 z6�9 �, \1\�a On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 H1.92 OX10.13007 CO PM10 *HAP 2012 0.1700 0.0700 00.4100 0.1500 1.02 *Highest HAP Emitted in ounds Five Year Violation History:None Date Letter Type Rule Violated Violation Resolution Date L__ Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested Neill Grading&Construction Company, Inc. March 27,2019 Page 2 Data Date submitted for initial review 4/8/2019 _IBEAM WARNING/OB,NOD,NOV,NRE X IBEAM Document Tracking: X IBEAM Inspection, list date inspected X IBEAM LAT/LONG,Facility Locked X IBEAM Inspection, list date draft is submitted X IBEAM LAT/LONG, Coordinates checked X IBEAM Inspection, pollutants/programs _IBEAM Complaint checked X IBEAM Planning,Next Inspection Date 3/1/2021 Directions: From MRO,travel 1-77 north to I-40 west to Hickory. Take exit 128 and turn right onto Fairgrove Church Road. Go past the hospital and turn left onto Tate Blvd. Turn right onto 26th Street Dr. SE. The plant is located on the right. The Office is located at 3050 First Ave. Ct. SE, (31 St.Place SE)which is one road east from 26t' Street Dr. Continue on 261h Street Drive until you come to the first street on your right. Turn right and continue past chain link fence until you come to Neill Properties. Safety Equipment: Hard hats are required when the equipment is operational at the crusher site. Safety shoes, safety glasses and ear protection are recommended when equipment is in operation as well. Safety Issues: Heavy equipment in operation.Always be cognizant of your surroundings. Facility Lat/Long: The"Maps of DAQ Regulated Facilities" is currently not accessible. However,the last compliance inspection conducted in 2018 indicated the coordinates were accurate.The coordinates will be checked during the next inspection cycle if the site is back online. Email Contacts: No changes were required to the email contacts. 1. The purpose of this site visit was to conduct a routine air quality inspection.This facility reprocesses building construction debris for the purpose of reuse as building raw materials.The facility is currently operating on an as-needed basis. (Discussed in detail further in the inspection) Mr. Jan Wilson, General Manager, accompanied me during this inspection. 2. Facile Contact Information: During the inspection I verified the facility contact information in IBEAM.No changes were needed. 3. Compliance history file review: No problems have been noted in the last five years by DAQ, prior to this inspection. The current compliance status is discussed in the following sections. 4. Observations of permitted air emission sources and control devices: 1 Neill Grading&Construction Company, Inc. March 27,2019 Page 3 Emission Emission Source Source ID Description ES-1 (NSPS) IFrock crusher(273 tons per hour maximum process rate)- 2(NSPS) screen(5 ft x 16 ft in a single deck configuration, 273 tons per hour maximum process rate) ES-10 (NSPS) [screen (4 ft x 8 ft in a double deck configuration, 273 tons per hour maximum process rate) ES-11 (NSPS),ES-12 conveyor(ID No.ES-13; 24" width; 273 tons per hour (NSPS),ES-13 (NSPS), maximum process rate); conveyor(ID No. ES-15; 26"width; ES-14(NSPS), ES-15 .273 tons per hour maximum process rate); conveyor(ID No. (NSPS),ES-3 (NSPS),ES-,ES-14; 29" width; 273 tons per hour maximum process rate); 4(NSPS),ES-5 (NSPS), 'five(5) conveyors(ID Nos. ES-3 through ES-5, ES-11, and ES- ES-6 (NSPS), ES-7 12; 30" width; 273 tons per hour maximum process rate, each); (NSPS),ES-8 (NSPS),ES- conveyor(ID No. ES-6; 36"width; 273 tons per hour maximum 9 (NSPS) process rate); conveyor(ID No. ES-7; 42" width; 273 tons per hour maximum process rate);two (2) conveyors (ID Nos. ES-8 and ES-9; 48" width; 273 tons per hour maximum process rate, each) GEN-1' (NSPS,NESHAP) 245 hp diesel-fired engine GEN-2 (NSPS,NESHAP) 125 hp diesel-fired engine GEN-3 (NESHAP) F 71 hp diesel-fired engine Observed: At the time of this inspection the plant was not in operation.There was one heavy equipment operator moving debris around in the yard, but the permitted equipment was not operating. The facility operated 11 days in 2016, 27 days in 2017, 25 days in 2018 and had not operated year to date. When the facility is operating the average throughput is around 70-100 tons a day. 5. Observations of insignificant air emission sources and control devices listed on the current ep rmrt: a. None listed. 6. Observations of air emission sources and control devices not listed on the current permit: a. None noted. 7. Compliance with specific permit conditions and limitations: a. Condition A.3. 15A NCAC 2D .0510"Particulates from Sand, Gravel or Crushed Stone Operations." Neill Grading&Construction Company, Inc. March 27,2019 Page 4 a. The Permittee of a sand, gravel, or crushed stone operation shall not cause, allow, or permit any material to be produced, handled,transported, or stockpiled without taking measures to reduce to a minimum any particulate matter from becoming airborne to prevent exceeding the ambient air quality standards beyond the property line for particulate matter, both PMIo and total suspended particulates. b. Fugitive dust-emissions from sand, gravel, or crushed stone operations shall be controlled by 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources." C. The Permittee of any sand, gravel,RAP or crushed stone operation shall control process-generated emissions: 1)From crushers with wet suppression; and 2) From conveyors, screens, and transfer points such that the applicable opacity standards in 15A NCAC 2D .0521 Control of Visible Emissions," or 15A NCAC 2D .0524 "New Source Performance standards" are not exceeded. Observed. The facility uses wet suppression on the crusher operations and also on the yard to minimize fugitive emissions. The equipment operator checks the operational status of the wet suppression equipment before each operating day. The MRO has not received any complaints regarding the facility. Compliance with this permit condition is indicated. b. Condition A.4.—This primary crusher is a jaw crusher rated at 273 tons per hour at an 8- inch crusher setting per the manufacturer's specifications as submitted. Any change from this crusher definition, other than like-for-like,will require a permit application to be submitted.The purpose of this stipulation to characterize the primary crusher and not limit production. Observed:I observed the 273 tons per hour to be the current rating as indicated in the permit. Compliance with the permit condition is indicated. C. Conditions A.5. and A.6. 15A NCAC 2D..0521, "Control of Visible Emissions". The facility is limited to 20 percent opacity for sources manufactured after July 1, 1971 and 40 percent opacity for sources manufactured prior to July 1, 1971. The equipment subject to NSPS Subpart 000 will be subject to the opacity limits specified therein. Observed. No visible emissions were observed at the facility. Compliance with this permit condition is indicated. d. Condition A.7. 15A NCAC 2D .0524"New Source Performance Standards." Generator (ID No. GEN-1; 245 hp diesel-fired) and Generator(ID No. GEN-2; 125 hp diesel-fired) are subject to NSPS Subpart IIII. Generators GEN-1 and GEN-2 are subject to opacity limits of 20% during acceleration mode, 15% during lugging mode and 50%during the peaks in either acceleration or lugging mode. The facility shall use fuel oil with a sulfur content of less than 500 ppm beginning October 1,2007. In accordance with 40 CFR 60.4207(a),the facility shall use diesel fuel with a sulfur content of less than 15 ppm i beginning October 1,2010. The facility shall operate and maintain the generators Neill Grading&Construction Company, Inc. March 27,2019 Page 5 according to the manufacturer's written instructions or procedures developed by the permittee that are approved by the manufacturer and be certified to the listed emission limits.Note: Generator GEN-3 is not subject due to the manufactured date of 1991. Observed. The facility maintains records of accepted equipment requirements and procedures. The facility provided records indicating that 15 ppm ultralow sulfur is used in the generators. The fuel is purchased from Bumgarner Oil Company.Records of maintenance activities are being kept by Mr. Jan Wilson. Gen-1, Gen-2 and Gen-3 were last serviced on December 19, 2018. Maintenance was performed within the required hourly interval. Belt and hose checks are conducted before each operating day. Extensive maintenance was conducted on the equipment in January of 2018. The facility has developed a checklist to better document the maintenance activities required in this stipulation. The crusher, bagfilter, conveyor belts, screening and other particulate emitting operations are required to have visible emissions testing based on Method 9. The bagfilter, if it exists, is required to have particulate matter testing based on Method 5. The equipment at this facility were constructed before April 22, 2008 and uses wet suppression. The crusher(ID No. ES-1) and screen(ID No. ES-2)and conveyors were tested for visible emissions,Method 9, on July 30, 2009. The screen(ID No.ES10) and conveyors(ID No. ES 11, 12, 13, and 15)were and tested for Method 9 on January 27, 2011. No bagfilter is operated at this site. The tests demonstrated compliance with the regulation. Since the equipment uses wet suppression,the equipment is not required to have repeated visible emissions testing after completion of the first round of testing. Compliance with this permit condition is indicated. e. Condition AX 15A NCAC 2D .0524 "New Source Performance Standards". The company must demonstrate compliance with NSPS Subpart IIII. The initial start-up date of the affected facility,postmarked within 15 days after such date must be submitted in writing to DAQ. Since all equipment was manufactured after August 31, 1983, but prior to April 22, 2008,the crusher is limited to 15% opacity and conveyor belts, screens and other affected sources are limited to 10% opacity. The facility is required to perform monthly periodic inspections of the wet suppression systems to verify that water is flowing and record the results of these inspections in a log book. In addition,Method 9 performance testing is required for all affected equipment. The facility may replace equipment on a like-for-like basis. _ Observed. The facility received a Notice of Violation September 18,2008, for failure to submit the required initial start-up date of the affected equipment. The permit application received on March 12,2009 was considered the notification for the crusher(ID No.ES- 1), screen(ID No. ES-2), and conveyors (ID Nos. ES-3 through ES-9). The Method 9 performance test on the original equipment was conducted on July 30, 2009. The initial start-up notification for screen (ID No. ES-10) and conveyors ES-11 through ES-15)was received by the MRO on August 19, 2010. Method 9 performance testing on this equipment was required within 180 days of the initial notification. The required Method 9 test was conducted on January 27, 2011. Since the facility uses wet suppression, it is exempt from conducting additional performance testing within 5 years of the initial test. The facility is conducting Neill Grading&Construction Company, Inc. March 27, 2019 Page 6 inspections of the water spray suppression system each day the crusher operates. Records of this activity are being recorded in a log book. Compliance with this permit condition is indicated. d. Condition A.9. Notification Requirement. The Permittee of a source of excess emissions that last for more than four hours and that results from a malfunction, a breakdown of process or control equipment or any other abnormal condition shall notify DAQ by 9:00 a.m. Eastern Time of the Division's next business day of becoming aware of the occurrence. Observed. Based on conversations with Mr. Wilson and a review of the records,no excess emissions have occurred at the facility. Compliance with this permit condition is indicated. e. Condition A.10. 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources." The Permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. Observed. The MRO has not received any complaints regarding dust from the facility and no fugitive dust emissions were observed at the time of this inspection. Compliance with this permit condition is indicated. f. Condition A.11 15A NCAC .l 111 "National Emission Standards for Hazardous Air Pollutants". The diesel fired generator(ID No. Gen-3) is subject to NESHAP Subpart 4Z as an existing source. The permittee shall be in compliance no later than May 3, 2013. The permittee shall: - change oil and filter every 500 hours of operation or annually, - inspect air cleaner every 1000 hours of operation or annually, and - inspect all hoses and belts every 500 hours of operation or annually. Observed. The facility.has three generators; only one(ID No. Gen-3) is subject to NESAHPS 4Z. The generator is used for running the ES-10 screen. All three engines have non-resettable hour meters. The work practice requirements (oil change, etc.)were conducted for the engine on December 19, 2018. Gen-3 also had maintenance conducted on January 1, 2018. The facility has developed a computerized checklist to better document the routine maintenance activities of this stipulation. Compliance with this permit condition is indicated. The hours on the three generators are as follows: Previous Current Hours Ran ID No. Description Meter Meter Since Last Previous Current Reading Reading Inspection Tune-Up Tune-Up Hours Hours Gen- 1 245 hp diesel-fired engine 3593.66 3949.00 355.34 1/1/2018 12/19/2018 Gen-2 125 hp diesel-fired engine 3885.70 4255.30 369.60 1/1/2018 12/19/2018 Gen-3 71 hp diesel-fired engine 2259.60 2367.40 107.80 1/1/2018 12/19/2018 Neill Grading&Construction Company,Inc. March 27,2019 Page 7 g. Condition A.12 15A NCAC .I 111 "Maximum Achievable Control Technology". Generator(ID No. GEN-1) and Generator(ID No. GEN-2) are subject to MACT subpart ZZZZ, "National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines." Observed. These generators (ID No. Gen-1 and Gen-2)have no additional requirements under this subpart since showing compliance with NSPS subpart IIII is sufficient to show compliance with subpart ZZZZ. Compliance with this permit condition is indicated. 8. NSPS/NESHAP Review: No gasoline storage tanks are located on the property. As such,the facility would not be subject to NESHAP 6C. There are no boilers, emergency generators or fire pumps located at the facility. 9. Summary of changes needed to the current permit: None. 10. Compliance assistance offered during the inspection: None. 11. Section 112(r) applicability: This facility does not appear to be subject to the requirements of the Chemical Accident Release Prevention Program, Section 112(r) of the Clean Air Act. 12. Compliance determination: Based on my observations,this facility appeared to be in compliance with the applicable air quality regulations at the time of the inspection. RCM:Ihe c: MRO File https://ncconnect.sliarepoint.com/sites/DAQ-MRO/Counties/CATAWBA/00553/fNSPECT 20190327.doex