AQ_F_0400045_20180130_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Hildreth Ready Mix,LLC
NC Facility ID 0400045
Inspection Report County/FIPS:Anson/007
Date: 01/31/2018
Facility Data Permit Data
Hildreth Ready Mix,LLC Permit 08715/G03
878 City Pond Road- SR 1142 Issued 7/30/2013
Wadesboro,NC 28170 Expires 6/30/2018
Lat: 34d 55.4970m Long: 80d 5.9570m Classification Small
SIC: 3273/Ready-Mixed Concrete Permit Status Active
NAILS: 32732/Ready-Mix Concrete Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Karl Hildreth Karl Hildreth Karl Hildreth
Owner Owner Owner
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 01/30/2018
Inspector's Name Mike Thomas
Inspector's Signature: Operating Status Operating
� Compliance Code Compliance-inspection
_ Action Code FCE
Date of Signature: On Site Inspection Result Compliance
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Total Actual emissions in TONS/YEAR:
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TSP S02 NOX VOC CO PM10 *HAP
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2012 0.7200 --- --- --- --- 0.2200 0.0610
j 2007 0.8240 --- --- --- --- 0.2410 0.0700
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*Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
j 03/21/2017 NOV Permit Late Report(excluding ACC) 03/13/2017
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Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
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L DIRECTIONS TO SITE: In Wadesboro,take Hwy 742 south for 3.5 miles to City Pond Road and turn
right. Hildreth Ready Mix is approximately 2 miles on the right. If no one is at the plant,take Hildreth
1 Road,which is just past plant,up to the office on the right.
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H. SAFETY: Standard FRO safety gear is required. The inspector should be mindful of vehicular and
heavy equipment traffic.
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M. FACILITY/PROCESS DESCRIPTION: Hildreth Ready Mix,LLC is a small concrete batch plant.
Cement is stored in silos and mixed with aggregate and sand(both stockpiled on site),all of which is 1
mixed with water inside a cement truck. The loadout and silos are controlled by a central dust collector. I
A second,bagfilter,which was previously used as a dedicated control for one of the silos is still in place,
but it is no longer operating. To produce the septic tanks,cement is poured into 1,000-gallon, 1,200-
gallon, or 1,500-gallon molds and allowed to cure for 28-30 days. The molds are removed and septic
tanks are delivered and installed on site.Although septic tanks are still produced on site,most of Mr.
Hildreth's business now is delivering concrete from his batch plant,which is operated on an"as needed" i
basis.
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The facility requested to have the air quality permit rescinded on 01 July 2016 under the newly adopted
2Q .0102(d)exemption. The facility's permit was rescinded on 19 July 2016. The rescission request was
an apparent error, and the facility subsequently requested to have the permit reinstated. The facility's air
permit was reinstated on 13 September 2016.
IV. PERMITTED EMISSION SOURCES:
One Concrete batch plant with fabric filter air pollution control system(s)installed on all sources;
1. One(1)cement mixing weigh hopper and loading operation;and,
2. Silos for cement and flyash storage.
Facility was not operating during the inspection.
V. INSPECTION CONFERENCE:
On 30 January 2018,I Mike Thomas of FRO DAQ,conducted a compliance inspection of the Hildreth Ready Mix,
LLC facility. I met with owner,Karl Hildreth and Office Manager,Chanel Little. This was a planned inspection to
assist with the facility's emissions inventory. We discussed the following:
a) I verified the FACTFINDR information:no changes are needed.
b) I viewed the maintenance logbook. Mr.Hildreth is getting better at keeping track of the maintenance he
performs on the baghouse.
c) I assisted Ms.Little with the DAQ emissions spreadsheet until the facility lost its internet connection and
we had to stop. !i
d) Production:
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Operating hours 0900-1700 Monday-Friday w/occasional Saturday
Employees 7 including drivers
Production(cu yd) 2017: 6,294.5
2016: 4,147
2015: 7,972.5
2014: 6,000
2013: 2,000
2012: 3,397
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VI. INSPECTION SUMMARY:
Mr.Hildreth led me on a tour of the facility which was not operating during the inspection. I observed
the area around the facility to be clean and well maintained. I observed the baghouse and did not see any
evidence of leaks or compromises in the system. I did not see any accumulations around the flyash silo
during the inspection.
VII. APPLICABLE AIR QUALITY REGULATIONS:
A. 15A NCAC 2D .0202—PERMIT RENEWAL AND EMISSION INVENTORY
REQUIREMENT—The permittee shall submit an application for renewal of the facility's permit no
later than 90 days prior to expiration, and shall include documentation of air pollutants emitted for the
2017 calendar year.
APPEARED IN COMPLIANCE: The facility submitted their previous emissions inventory and
permit renewal before the submittal deadline. The facility's current air permit will expire on 30 June
2018. I assisted the-facility with their emissions inventory and they are aware of the due date.
B. 15A NCAC 2D .0515—PARTICULATES FROM MISC.INDUSTRIAL PROCESSES—
Particulate emissions shall not exceed allowable emission rates as calculated by the following
equations:
E=4.10 * (P)0.67 for P<30 tons/hr,or
E=55 * (P)0-1-40 for P>30 tons/hr
APPEARED IN Compliance was determined during the most recent permit review
based on operating the source as described in the permit conditions. No changes have been made to
operations since that determination.
C. 15A NCAC 2D .0521—CONTROL OF VISIBLE EMISSIONS—Visible emissions shall not
exceed 20%opacity.
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APPEARED IN COMPLLANCE. The facility was not operating during the inspection. I did not see
any indication of issues with visible emissions at the time of inspection.
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D. 15A NCAC 2D .0535—NOTIFICATION REQUIREMENT—Notify DAQ in the event of excess
emissions lasting longer than 4 hours resulting from malfunctions,breakdowns,or abnormal
conditions.
APPEARED IN COMPLLANCE Mr. Hildreth stated that there had not been any operational
I exceedances that would have required notification to this office.
E. 15A NCAC 2D .0540—PARTICULATES FROM FUGITIVE DUST EMISSION SOURCES—
Fugitive dust emissions shall not contribute to substantive complaints, or excessive dust emissions
across the property boundary.
APPEARED IN COMPLLANCE. No fugitive dust concerns at the property boundaries were noted
during the inspection. Mr.Hildreth stated that he has not received any complaints related to dust.
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F. 15A NCAC 2D .0611-FABRIC FILTER REQUIREMENT—Particulate emissions controlled by
fabric filters; annual internal inspections; record keeping.
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APPEARED IN COMPLIANCE: Mr.Hildreth performs the maintenance himself Mr.Hildreth
stated that he removes the bags, inspects them for damage,rinses them, and lets them dry before
reinstalling them. He uses a pump truck to pump out any collected cement,then he sprays the slurry
onto his lawn,which he claims helps the grass grow. Mr. Hildreth conducted an internal inspection
of the.baghouse and cleaned the bags on 15 January 2018.
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G. 15A NCAC 2D.1104—TOXIC AIR POLLUTANT CONTROL REQUIREMENTS—Arsenic
emissions shall not exceed the AAL. Concrete production limit based on distance to property
boundary(35,000 cubic yards at 75 feet),which shall be marked. Monthly recordkeeping.
Notification of changes. Annual reporting. 1
APPEARED IN COMPLIANCE: The nearest property boundary is marked and has been verified at
—75 feet which limits the facility to 35,000 cubic yards of production annually. Mr.Hildreth keeps a
running log of concrete produced each day, and there is a spreadsheet available which shows the
monthly and annual totals;the facility produced 6,294.5 cubic yards in 2017. Mr.Hildreth stated that
there have been no changes to the facility. The annual report was received late,on 13 March 2017,
and a Notice of Violation was issued on 21 March 2017. The violation was immediately resolved
since the report was received. The facility's next annual report is due on 1 March 2018.
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H. 15A NCAC 2Q .0310—GENERAL PERMIT CRITERIA—The facility must meet the following
criteria to qualify for a general permit: 1)No emissions sources operated other than those listed; 2)
facility not subject to regulations other than those covered by the general permit; 3)facility is located
in one of the listed counties;4)maximum hourly throughput does not exceed 138 cubic yards per
hour;and 5)the facility does not exceed the maximum annual production rate based on distance to the
property line(35,000 cubic yards at 75 feet).
APPEARED IN COMPLIANCE: The facility appears to qualify for a general permit. No other
emission sources other than those listed were noted,and the facility does not appear to be subject to
any regulations, State or Federal, other than those listed in the general permit. The facility is located
in Anson County,which is listed in the permit and covered by generalized modeling. The facility's
maximum throughput is 100 cubic yards per hour,which is much less than the maximum permitted j
throughput, and the annual throughput, 6,294.5 cubic yards in 2017, is also much less than the i
35,000-cubic yard limit: !"
I. 15A NCAC 2Q.0711—TOXIC AIR POLLUTANT EMISSION LIMITATIONS—Emissions of
toxic air pollutants shall not exceed the listed limitations without first obtaining a permit and
demonstrating compliance with 2D .1100.
APPEARED IN COMPLIANCE: The listed TPERs are based on a maximum production rate of
150,000 cubic yards per year. The facility's annual throughput, 6,294.5 was much less than this limit,
therefore compliance is indicated.
VIII. NON-COMPLIANCE HISTORY SINCE 2010:
03/21/17 NOV issued for late annual reporting.
03/28/16 NOD issued for late annual reporting.
05/28/10 NOV issued for late annual reporting.
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IX. RISK MANAGEMENT(112r): This facility does not store any 112(r)subject materials above threshold
quantities.Therefore,it is not required to maintain a written Risk Management Plan(RMP).
X. CONCLUSION AND RECOMMENDATIONS:
Hildreth Ready Mix,LLC. appeared to be IN COMPLL4NCE with the conditions in their current air
permit, on 30 Janaury 2018
{ PINK SHEET ADDITIONS:
None.
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