AQ_F_0400005_20170421_CMPL_NOV-NRE

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
MICHAEL A. ABRACZ[NSKAS
Air Quality Acting Director
ENVIRONMENTAL QUALITY
21 April 2017
CERTIFIED MAIL
RETURN RECIEPT REQUESTED
Mr. Colin Clampett, President
333 North Greene Street, Suite 201
Greensboro,NC 27401
Subject: Notice of Violation/Recommendation for Enforcement—
15A NCAC 2D .0521 —Excessive Visible Emissions;
Adams an Old Castle Company—Lilesville Air Permit No. 01759R22
Lilesville,NC,Anson County 06/04-00005 Fee Class: Synthetic Minor
Dear Mr. Clampett:
On 13 April 2017, Jeffrey Cole, of the NC Division of Air Quality Fayetteville Regional
Office (FRO DAQ), observed what appeared to be excessive visible emissions (VE) coming from
your facility. He first observed the emissions around 9AM, in route to another facility, and then
again around 12:30PM, upon his return to the area. From the haul road at the southeast of your
facility, Mr. Cole noted excessive dust being emitted from the small house-like structure atop your
rock silo and a sand silo containing the shaker screen (Source ID No. ES03; —112 feet of the ground)
and also from the near ground level exhaust stack from the associated bagfilter (ID No. BH1A; --7
feet of the ground). Since the dust appeared to exceed the visible emissions standard, Mr. Cole
proceeded to do a 19-minute visible emissions evaluation (VEE) on both emission points
concurrently. He recorded two 6-minute averages in excess of the 20% VE standard on ES03: 26%
and 23% opacity, and three 6-minute averages in excess of the 20% VE standard on BH1A: 27%,
29%, 32% opacity. After performing the VEE, Mr. Cole spoke with Mr. Jeff Scully, Maintenance
Manager, who stated that no one at the facility had been aware of the excess emissions coming from
these sources. Mr. Cole then met with Mr. Kevin Tucker, Plant Manager, who provided records that =
showed that inspection and maintenance has been performed routinely on the BH1A. Mr. Tucker
also stated that the seals on ES03 were planning to be replaced soon. Mr. Cole advised Mr. Tucker
and Mr. Scully that the visible emissions that he observed appeared to exceed the visible emissions
standard in your permit.
The cited visible emissions regulation, paragraph A.5 in your air permit, limits opacity from
all sources at your facility to 20%, and allows one exceedance per hour; therefore, both sources were
in violation. Also of concern is that no one at the facility was aware that there was excessive dust
coming from these sources and it is also not clear how often such observations are made by your
employees.
State of North Carolina I Environmental Quality I Air Quality
Fayetteville Regional Office 1 225 Green Street,Suite 7141 Fayetteville,North Carolina 28301
9104333300 T 1 910 485 7467 F

NRE -Adams an Old Castle Company—Lilesville
21 April 2017
Page 2
As stated in the "subject' above, this letter represents not only a Notice of Violation for
failure to comply with the permit condition cited above, but puts you on notice that this office is
preparing an enforcement report addressing the violations observed. The above violations and any
future violation of an air quality rule are subject to the assessment of civil penalties as per North
Carolina General Statute 143-215.114A. This General Statute provides that civil penalties of not
more than twenty-five thousand dollars ($25,000) may be assessed against any person who violates
any classification, standard, or limitation established pursuant to General Statute 143-215.107, "Air
Quality Standards and Classifications." In addition, each day of continuing violation after written
notification from the Division of Air Quality shall be considered a separate offense.
Please respond to this letter no later than 5 May 2017. Include in your response the
measures you plan to implement to continuously meet the opacity standards for these sources and the
date by which you anticipate achieving compliance. After the above date, in lieu of any mitigating
circumstances brought to our attention, this office will submit the enforcement report to the Director
of the Division of Air Quality, including recommendations for the assessment of appropriate civil
penalties. Please be advised that neither this letter, nor any subsequent action, absolve you from
responsibility for any violation or damage to public or private property or from any enforcement
action available to this agency.
We appreciate your immediate attention to this environmental concern. If you have any
questions regarding the cited violations, please contact Jeffrey Cole, Environmental Engineer, or
Heather Carter, Compliance Coordinator, at(910) 433-3300.
i
5erly,
Steven F. Vozzo
Regional Air Quality Supervisor
NCDEQ,Division of Air Quality
SFV/jdc
cc: FRO Facility File -
Enforcement File
f
State of North Carolina.I Environmental Quality I Air Quality
Fayetteville Regional Off ice 1 225 Green Street.Suite 7141 Fayetteville,North Carolina 28301