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HomeMy WebLinkAboutAQ_F_0400005_20170110_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: 01/18/2017 Facility Data Permit Data Adams an Old Castle Company-Lilesville Permit 01759/R21 351 Hailey's Ferry Road Issued 5/9/2016 Lilesville,NC 28091 Expires 4/28/2017 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 01/10/2017 Inspector's Name Mike Thomas Inspector's Signature: Operating Status Operating �TitC Compliance Code Compliance-inspection Action Code FCE Dat6 of Signature: On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2010 0.4400 0.0100 0.8800 0.0500 0.7400 0.2300 31.49 2005 1.40 -- 0.1300 0.0100 0.1100 0.4800 4.85 'Highest HAP Emitted(inpounds) Five Year Violation History:None Date Letter Tvoe Rule Violated Violation Resolution Date 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 I801),where there is a large antique cart in a yard on the right and a sign for Welika Fish Camp on the left.Tura left,go almost 0.2 miles,and thenjust 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 packaged/bagged according to the specified concrete mix and customer. The company has 20 employees(including drivers)and operates 6AM—2:30PM 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 sron �', Emission Source Control Control System Emrs ,- L Source ID Description System ID Descriptio Drying 6foration,consisting of: FNawralMo.2 fuel oil-firedmax heat input)sandBagfiher ES30ryer(50 tons per hour BHIA (3,825 square feet of filter area) mum capacity) ing with 0/VE Production Line 1,consisting of: Portland cement silo,Line 1 Bagfilter SF22 Operating with 0%VE BH22 (156 square feet of filter area) SF23 Recycled cement silo,Line 1 BH23 Bagfilter Operating with 0%VE (156 square feet of filter area) Fly ash silo,Line 1 Bagfilter SF24 Operating with 0% BH24 (156 square feet toof filter area) SF25 No-mix cement silo,Line 1 BH25 Bagfdter Operating with 0%VE F (156 square feet of filter area) Rock and sand bucket conveyor operation including a rock silo and Bagfiher ES03 a sand silo BHIA (3,825 square feet of filter area) Operating with 0%VE Cement handling operation Esol (bagging,weighing,mixing),Line B1401 Bagfilter 1 (3,840 square feet of filter area) Operating with 0%VE Production Line 2,consisting of: 40-ton capacity Portland cement Bagfiher Operating SF40 s with 0%VE!to,Line 2 BH40 (156 square feet of filter area) 80-ton capacity Portland cement Bagfilter SF80 silo,Line 2 BV80 (264 square feet of filter area) Not installed Emission - Emission Source Control Control System Description SystemED Description 145-ton cam pacity Portland cement SF145 silo, Line 2 BVI45 Bagfilter Not installed (264 square feet offilter area) SF41 Rock silo,Line 2 BH41 Bagfilter Operating with 0%VE [(156 square feet offil[er area) SF42 Send silo split,Line 2 BH42 Bagfilter 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 Recycledcementsilo,Lin e2 BH52 Bagfilter Operating with 0%VE F (156 square feet offilter area) ES 18 Rock screen from sand,Line 2 BH13 Bagfilter Not operating F (1,200 square feet of filter area) Cement handling operation ES02 (bagging,weighing,mixing),Line B1102 Bagfilter 2 r(190 0 square feet offilter are) Operating with 0%VE 5) Inspection Conference On 10 January 2017,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) I reminded Mr. Tucker about the facility's upcoming deadline for emissions inventory and permit renewal. He stated that he was aware of the deadline and that the company had decided to use an outside contractor to handle it this time. c) Production: 2016 52,416,000 3,4070,000 - 18,000,000 2015 25,138,000 - 8,176,000 7,442,000 20% 24,015,260 4,574,860 - 662,280 20 P 19,429,672 - - - 2012 - - 2011 - 5,017,514 - - 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 been allocated money from the corporate office to put in a Hi Vac system to assist with clean up in the bagging area. He went on to say that the system would have 4 to 6 drops where spilled product can be collected and recycled back into their process. I informed him that the system would need to be evaluated to determine if permitting would be required for the unit. (I later discussed the project with Greg Reeves,who recommended I provide Mr.Tucker with the form to do a 2Q .318 Modification). I observed all of the bagftlters and transfer points outside of the building and observed no issues with any of them. 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 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 currently has a deadline of 28 January 2017 for emissions inventory and permit renewal. I confirmed that Mr.Tucker was aware of the deadline and he emailed a reminder to the consultant while I was conducting the inspection. 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) AA 15A NCAC 2D.0516 SULFUR DIOXIDE CONTROL REQUIREMENT—SO2 emissions from the combustion sources shall not exceed 2.3 Ibs/mm BTU. APPEARED IN COMPLLANCE—The AP42 emissions factor for No.2 fuel oil is 0.507 lbs/mmBtu; natural gas is 0.001 Ibs/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. APPEARED IN COMPLIANCE—Mr.Tucker stated that there have been no instances of excess emissions during the past year. Visual observations and records reviewed support that statement. 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—We saw 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.815A NCAC 2D.0611 BAGFD.TERREQUIREMENTS—particulate matter emissions shall be controlled as described in the permitted equipment list, the pemrittee 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.Bagfilter BH1A had full bag replacement and internal inspection on 22 October 2016.All of the bagfilters associated with Production Line I had bag replacements and internal inspections on 30 October 2016. The bagfilters associated with production Line 2 were inspected internally on 30 October 2016. No bags were replaced during this inspection. 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 PMm 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 BAGFILTER REQUIREMENTS. APPEARED IN COMPLIANCE— Facility met the requirements by performing the required inspections, maintenance, and record keeping as prescribed in 15A NCAC 2D .0611 BAGFILTER REQUIREMENTS. See A.8 above. 8) Non-compliance History Since 2010 Jan. 2012-NOD Failure to renew Air Permit 9) 112RStatus 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 10 January 2017. Pink Sheet:No comments. /mst