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Home My WebLink AboutAQ_F_0400005_20180613_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Adams an Old Castle Company-Lilesville NC Facility ID 0400005 Inspection Report County/FIPS:Anson/007 Date: 06/21/2018 Facility Data Permit Data Adams an Old Castle Company-Lilesville Permit 01759/R22 351 Hailey's Ferry Road Issued 3/8/2017 Lilesville,NC 28091 Expires 2/28/2025 Lat: 34d 57.5360m Long: 79d 57.4490m Classification Synthetic Minor SIC: 3272/Concrete Products,Nec Permit Status Active NAICS: 32739/Other Concrete Product Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Kevin Tucker Colin Clampett Doug Fouts Plant Manager President EH&S Manager (704)848-4144 (336)275-9114 (336)275-9114 Compliance Data Comments: Inspection Date 06/13/2018 Inspector's Name Mike Thomas Inspector's Signature: Operating Status Operating Compliance Code Compliance-inspection r_ Action Code FCE Date of Si nature: On-Site Inspection Result Compliance Z-v e Total Actual emissions in TONSIYEAR: TSP S02 NOX VOC CO PM10 *HAP 2015 3.07 --- 0.7900 0.0400 0.6600 0.9800 28.30 2010 0.4400 0.0100 0.8800 0.0500 0.7400 0.2300 31.49 *Highest HAP Emitted inpounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 04/21/2017 NOV/NRE 2D .0521 Control of Visible Emissions 05/05/2017 Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested 1) Directions From Wadesboro,take US 74 West until just after crossing the Pee Dee River. Go—5 more miles to Hailey's Ferry Road(crossroads SR 1801),where there is a large antique cart in a yard on the right and a sign for Welika Fish Camp on the left. Turn left,go almost 0.2 miles, and then just before the railroad tracks,take a left onto facility's dirt drive. Proceed around the truck loading area to the parking lot. Main office is directly in front of the parking lot and there is visitor parking to the right of the entrance. 2) Safety Considerations Standard DAQ safety equipment, including vest. Watch for forklifts and truck traffic throughout the whole facility during inspection. Stairs and ladders are slippery because of cement dust 3) Facility and Process Description Adams is a mineral mixing and packaging facility that primarily manufactures bagged concrete. It also produces play sand, all-purpose sand, and mortar. The processing plant is on contiguous property with the W. R.Bonsal mine. Raw materials are delivered on site,processed and dried through the sand and gravel dryer and stored in designated silos. They are then blended and packagedibagged according to the specified concrete mix and customer. The company has 20 employees(including drivers)and operates 6AM—2:3OPM Mon-Fri,40 hrs/wk, 52 wks/yr. This facility is permitted under Air Permit No. 01759R21, effective from 9 May 2016 until 28 April 2017.Daniel Thoma conducted the last compliance inspection on 16 June 2016. 4) Permitted Emission Sources Emission Emission Source Control Control System Source ID Description System ID i Description Drying Operation,consisting of: --------------- Natural gas/No.2 fuel oil-fired (15 mmBtu max heat input)sand Bagfilter ES30 and gravel dryer(50 tons per hour BH1A (3,825 square feet of filter area) maximum capacity) Operating with 0%VE Pro_duction Line 1,consisting of: SF22 Portland cement silo,Line 1 BH22 Bagfilter Operating with 0%VE (156 square feet of filter area) SF23 Recycled cement silo,Line 1 BH23 Bagfilter Operating with 0%VE (156 square feet of filter area) SF24 Fly ash silo,Line 1 BH24 Bagfilter Operating with 0%VE !�— (156 square feet of filter area) SF25 No-mix cement silo,Line 1 BH25 Bagfilter Operating with 0%VE (156 square feet of filter area) Rock and sand bucket conveyor ES03 operation including a rock silo and BH1A Bagfilter a sand silo (3,825 square feet of filter area) Operating with 0%VE Cement handling operation ESO1 (bagging,weighing,mixing),Line BHO1 Bagfilter 1 (3,840 square feet of filter area) Operating with 0%VE FProduction Line 2,consisting of: Emission Emission Source Control Control System j Source ID Description System ID Description 40-ton capacity Portland cement Bagfilter SF40 silo,Line 2 BH40 (156 square feet of filter area) Operating with 0%VE 80-ton capacity Portland cement Bagfilter SF80 silo,Line 2 BV80 Not installed (264 square feet of filter area) 145-ton capacity Portland cement ' Bagfilter SF145 silo,Line 2 BV145 Not installed (264 square feet of filter area) SF41 Rock silo,Line 2 FBH41 Bagfilter Operating with 0%VE I (l56 square feet of filter area) SF42 Sand silo split,Line 2 BH42 Bagfilter F Operating with 0%VE �'� [(156 square feet of filter area) SF43 Fly ash silo,Line 2 BH43 Bagfilter Operating with 0%VE (156 square feet of filter area) SF44 Type S cement silo,Line 2 BH44 Bagfilter Operating with 0%VE (156 square feet of filter area) SF52 Recycled cement silo,Line 2 BH52 Bagfilter Operating with 0%VE [(156 square feet of filter area) ES 18 Rock screen from sand,Line 2 BH 13 Bagfilter Not operating (1,200 square feet of filter area) Cement handling operation ES02 (bagging,weighing,mixing),Line 131-102 Bagfilter 2 (1,900 square feet of filter are) Operating with 0%VE 5) Inspection Conference On 13 June 2018,I Mike Thomas of FRO DAQ, conducted a compliance evaluation inspection of the Adams Old Castle Company—Lilesville facility. I met with Kevin Tucker, Plant Manager for the facility. We discussed the following: a) Verified the FACFINDR information: no changes are required. b) Mr. Tucker informed me of several improvements that the facility had made to help with controlling dust and improving environmental conditions at the plant. These included overhauls of the baghouse infrastructure and the addition of a central vacuum system to improve the indoor air quality in the bagging operation. c) Production: Year Portland Cement Masonry Content Type 8(Ibs.) Fly Ash(Ibs.) (lbs.) (lbs.) 2017 52,416,000 3,4070,000 - 18,000,000 2016 52,416,000 3,4070,000 - 18,000,000 15 25,138,000 - 8,176,000 7,442,000 2014 24,015,260 4,574,860 - 662,280 2013 19,429,672 - - 2012 - - - MI1 _ 5 017 51a _ 6) Inspection Tour Mr.Tucker led me on a tour of the facility which was operating. I observed the interior location where the final product is bagged and loaded onto pallets for distribution. Mr. Tucker informed me that the facility had recently installed a Hi Vac system to assist with clean up in the bagging area. The system has 6 drops where spilled product can be collected and recycled back into their process. The Hi Vac system is located in a building across from the bagging area and has a collection bin to capture material to be recycled back into the process. It does not vent outside of the building it is housed in. Mr. Tucker showed me the improvements/repairs that had been made to the ductwork associated with the baghouses. These upgrades were purely structural and did not increase emissions. I observed the drum dryer to be in good condition,with no leaks or holes. I asked Mr.Tucker what their procedure was for receiving dry material into the silos. He stated that drivers are instructed to fill silos at 10 to 12 psi to avoid exceeding the rate of the bagfilters . Trailers have an over pressure valve that is triggered if the fill pressure exceeds 15 psi. 7) Permit Stipulations a) A.2 15A NCAC 2D.0202&2Q.0304-PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT-The facility shall submit a permit renewal request and a completed air emissions inventory at least 90 days prior to permit expiration. APPEARED IN COMPLIANCE— The facility submitted their emissions inventory on 18 January 2017 and the permit renewal on 23 January 2017,before the required deadline. The facility's next deadline for submittal will be December 2024 for the 2023 calendar year. b) A.3 15A NCAC 2D.0515 PARTICULATE CONTROL REQUIREMENT—Particulate matter emissions from sources shall not exceed the allowable rates as defined in the permit. APPEARED IN COMPLIANCE—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) A.4 15A NCAC 2D.0516 SULFUR DIOIIIDE CONTROL REQUIREMENT—S02 emissions from the combustion sources shall not exceed 2.3 lbs/mm BTU. APPEARED IN COMPLIANCE—The AP-42 emissions factor for No. 2 fuel oil is 0.002 lbs/mmBtu; natural gas is 0.001 lbs/mmBtu. Facility is only burning natural gas. d) A.5 15A NCAC 2D.0521 VISIBLE EMISSIONS CONTROL REQUIREMENT—Visible emissions from the emission sources shall not exceed 20% opacity. APPEARED IN COMPLIANCE No VE observed from any sources during the inspection. e) A.6 15A NCAC 2D.0535"NOTIFICATION REQUIREMENT"—The facility shall notify the DAQ if there are excess emissions that last for more than four hours due to malfunction, breakdown of equipment,or other abnormal conditions. DEFFICIENCY NOTED—On 13 April 2017,Jeff Cole of FRO DAQ observed excessive visible emissions from the facility while traveling to another nearby facility. Mr. Cole's observations resulted in the facility receiving a Notice of Violation/Recommendation for Enforcement. Mr.Tucker failed to report the excessive emissions prior to them being observed by Mr. Cole. f) A.7 15A NCAC 2D.0540 FUGITIVE DUST CONTROL REQUIREMENT- "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. APPEARED IN COMPLIANCE—I observed no excess fugitive dust emissions during our inspection. The roads are gravel/sand. Mr.Tucker stated that he has not received any dust complaints. g) A.8 15A NCAC 2D .0611 BAGFILTER REQUIREMENTS—Particulate matter emissions shall be controlled as described in the permitted equipment list,the permittee shall perform, at a minimum,an annual internal inspection of each particulate collection system. The permittee shall also perform periodic inspections and maintenance as recommended by the equipment manufacturer. The results of all inspections maintenance activities shall be recorded in the logbook and kept onsite. APPEARED IN COMPLIANCE—Separate logbooks are kept for each bagfilter system. Facility personnel perform monthly internal inspections.All entries were up to date and complete.The last annual internal inspection of all the baghouses took place on 31 May 2018. Piping,diaphrams, and solenoids were replaced on each of the baghouses at that time. h) A.9 15A NCAC 2Q.0315 LIMITATION TO AVOID 15A NCAC 2Q.0501(Title V)- Pursuant to 15A NCAC 2Q .0315 "Synthetic Minor Facilities,"facility-wide PMIo emissions shall be less than 100 tons per consecutive 12-month period. Facility complies with this limitation by properly operating and maintaining their bagfilters and record keeping in accordance with 15A NCAC 2D .0611 BAGFIL,TER REQUIREMENTS. APPEARED IN COMPLIANCE— Facility met the requirements by performing the required inspections,maintenance, and record keeping as prescribed in 15A NCAC 2D .0611 BAGFI LTER REQUIREMENTS. See A.8g above. 8) Non-compliance History Since 2010 January 18, 2012-NOD Failure to renew Air Permit April 21,2017—NRE for excessive visible emissions. 9) 112R Status This facility does not store chemical compounds that require a written risk management plan under the Clean Air Act, Section 112R. 9) Compliance Statement and Recommendations Adams an Old Castle Company—Lilesville appeared to be in compliance with the conditions in their current air permit on 13 June 2018. 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