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NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Adams an Old Castle Company-Lilesville
NC Facility ID 0400005
Partial Inspection Report County/FIPS:Anson/007
Date: 04/19/2017
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,Nee 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 04/13/2017
Inspector's Name Jeffrey D.Cole
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code PCE
Date of Signature: ��// I 7 On-Site Inspection Result Violation
Total Actual emissions in TONS/YEAR: t�
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:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE: None
Date Test Results Test Method(s) Source(s)Tested
I. 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.
II. 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
M. FACILITY AND PROCESS DESCRIPTION:
Adams an Old Castle Company—Lilesville is a mineral mixing and packaging facility that primarily
manufactures bagged concrete. It also produces play sand, all-purpose sand, and mortar. 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.
IV. INSPECTION SUMMARY:
On 13 April 2017, I, Jeffrey Cole of the NC Division of Air Quality,Fayetteville Regional Office,
was proceeding to a separate facility to conduct their annual compliance inspection. At
approximately 9:00, I was driving down Hailey's Ferry Road, south of US 74 West,when I passed the
Adams an Old Castle Company facility and noticed that the facility was emitting excess dust. I
decided at that time to continue to the other facility I planned on inspecting. While on the roof of that
other facility, at around 1:00,I noted that the excess dust emissions from the Adams an Old Castle
Company facility were continuing as they were still visible above the tree line. After completing my
compliance inspection at the other facility,I proceeded north on Hailey's Ferry Road and again
observed the excess dust emissions and decided to conduct a Method 9 visible emissions(VE)
observation. I chose an observation position conforming to Method 9 requirements which was
located along a haul road at the southeast of the facility,
Once in position to observe the emissions,I noted excess dust emitting from 2 sources. The first
source of emissions was a small house-like structure atop what I later identified as their rock silo and
sand silo,containing the shaker screen(Source ID No.ES03;—112 feet of the ground)and a second
source of emissions was a near ground level exhaust stack from Bagfilter(later identified as ID No.
BH1A;—10 feet of the ground). I proceeded to conduct a 19-minute visible emissions evaluation
(VEE)on both emission points concurrently. While conducting the VEE,I was approached by Mr.
Jeff Scully,Maintenance Manager of the facility. I told Mr. Scully that I would talk with him after
the VEE was completed. After the VEE was complete,I advised Mr. Scully that the visible emissions
that he had observed appeared to exceed the opacity standard in their permit. Mr. Scully and I then
entered the facilities offices and met with Mr. Kevin Tucker,Plant Manager. Mr. Tucker provided
me with the status of operations at the facility during my inspection. The facility was operating as
follows:
i
Production:
g —40,000 bags of concrete per day
Overall material processing rate:
—2.8 million lbs per day
8
Consisting of:
—504,000lbs of cement
—1,400,000 lbs of sand
—896,000 lbs of rock
Mr. Scully and Mr.Tucker then provided records that showed that inspection and maintenance was
being performed on the bagfilter. The most recent internal inspection of the bagfilter(ID No. BH1A)
was conducted on 4/2/17. Mr. Tucker stated that during that inspection all bags and internal
components appeared to be in good shape and working properly. Mr.Tucker stated that all 140 bags
in the bagfilter had been changed on 10/22/16. Finally, Mr. Tucker stated that the ID fan following
the bagfilter had failed on 2/3/17. The company was able to procure an identical replacement ID fan
that same day and had it installed on the same date as the failure. Mr. Scully told me that amongst the
maintenance work they were performing onsite that week,which included refurbishing and
reinstalling several silos,was to replace the seals on the small house-like structure atop the rock silo
and a sand silo containing the shaker screen from where I had observed the excessive dust emissions.
Finally, upon my request they also produced a copy of the facility's current air quality permit. I
showed Mr. Scully and Mr.Tucker the applicable permit stipulation(A.5) and noted that the visible
emissions that he had observed appeared to exceed the opacity standard in their permit. I also stated
that the facility would be contacted by mail about what action would be taken by DEQ.
V. REGULATORY REVIEW:
The facility's current permit stipulation A.5 (15A NCAC 2D .0521) states,
"... visible emissions from the emission sources, manufactured after July 1, 1971, shall not be more
than 20 percent opacity when averaged over a six-minute period, except that six-minute periods
averaging not more than 87 percent opacity may occur not more than once in any hour nor more than
four times in any 24-hour period."
After returning to the FRO,I ran a calculation of 6-minute averages from the instantaneous readings
every 15 seconds that I had recorded during the inspection. The three highest 6 minute averages from
the small structure atop the rock silo and a sand silo containing the shaker screen were 26%,23%and
11%opacity, respectively. Allowing for one of the two 6-minute opacity averages per hour being
above 20%opacity,as stated in the permit,the second 6-minute opacity average above 20%opacity,
on this source in the same hour, is a single violation of 15A NCAC 2D .0521. The three highest
6-minute averages from the bagfilter exhaust stack,were 27%,29% and 32%opacity, respectively.
Allowing for one of the three 6-minute opacity averages per hour being above 20% opacity, as stated
in the permit,the second and third 6-minute opacity averages both being above 20%opacity, on this
source in the same hour, constitutes two violations of 15A NCAC 2D .0521.
VI. CONCLUSION:
I recommend sending a NOV/NRE letter to Adams an Old Castle Company—Lilesville for two
violations of 15A NCAC 2D .0521.
ENCL: VEE evaluation(readings,calculation of 6-minute averages,map, 2 photo pages)
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VISIBLE EMISSION OBSERVATION FORM
Company Name�Ayftf �/ 06G GASlt B C/1ff3aH%LICtS Observation Date Time Zone Start Time End Time
q h31n
Facility Name s4N GLpC45TCF GO, -L1Zj4SV14Ze1096AA
Street Address 31Y j4WCsy15',E/eky 47,0. Seconds econds
p Min. 00 15 30 45 Min. 00 15 30 45
l City(/ SU 44d State � zip
Z�09/
Key Contact/Phone Source ID DSO l is
31 21)
2 / 7t/ckBllL BAIQ 2 2 32 �d
3 33 2
Process Equipment Unit# Operating Mode -a 34
cs03 c!"S3G A�9Wt- 5 3s
Control Equipment Operating Mode 6 36
�osGi�T 6N1 Q NoRM4L 7 z 37
8 38
39
Describe Emission Point(S).91W& �y� ,eJff S IgtalW7PIAC 10 9 40
Jb
Cr9,10 ApDSMpo sAOcWPX/wNiW SA("w$, Al rx4.�s'r /asQ 11 / / at -V
Height Above Ground bevel Height Relative to Observer /VXr( 12 / yf, 3t 42 z
Start Endl11///o Start /tL' Q ' End 1(z/ 13 ' Zd /$ / d 43 3
Distance From Observer Direction From Observer 14 / 6 44 Z�
Start 7 End 7$ Start End 15 / 45 O
16 G o 46 G
Describe Emission ' 17 o 47 35
Start _. End y e- 18 48 35 O
Emissions Color Water Droplet Plume 19 49 O
Start M467 End h/l(fC Attached o Detached a None 20 50
Point In the Plume At Which Opacity Was Determined 21 51
Start End 22 52
Describe Plume Backgrounds ._, 23 53
Start ova r'� � �° End SiQM7E 24
Background Color Sky Conditions 54
Start gc C End&ee Start ctiG.1? End CGS 25 55
Wind Speed Wind Direction _ 26 56
Start Z-E En� s Start 1,)e End WE 27 57
Ambient Temp. Wet Bulb Temp RH Percent 28 58
Start 77 End 77 29 59
30 60
Source Layout Sketch Draw North Arrow
ylb5 ❑TN OMN Observer's Name(print)
JtACR&Y C046
V 8� Observer's Signature Date
ObservaXon Point ��//
GC / C10 Q
//1 I�EET Certified By e7A Date
y3 3770
FEET
Observer's Position
sidew.w Form Number Page / of /
140o StackCE_ Continued on VEO Form Number
- - - - - - _ --_- -_ plume
Su Locatlont a Sun
Wind
longitude LatXude Declinatlon
—-79.957y 97 I3y.9S87o6'
Additional Information:
Adams an Old Castle Company - Lilesville 0400005 13-Apr-08
Rock and sand bucket conveyor
Source E03 operation including a rock silo
VEE Calculation Form and a sand silo
Actual Minute Minute VE% 6-min avg Count
12:30 1 25
20
25
25
12:31 2 30
25
25
30
12:32 3 25
25
20
20
12:33 4 30
30
25
20
12:34 5 30
30
30
25
12:35 6 25
25
30 23
30 26.0 24
12:36 7 25 26.0 24
25 26.3 24
30 26.5 24
30 26.7 24
12:37 8 30 26.7 24
30 26.9 24
30 27.1 24
30 27.1 24
12:38 9 25 27.1 24
30 27.3 24
25 27.5 24
25 27.7 24
12:39 10 30 27.7 24
25 27.5 24
20 27.3 24
25 27.5 24
12:40 11 15 26.9 24
10 26.0 24
10 25.2 24
10 24.6 24
12:41 12 15 24.2 24
15 23.8 24
25 23.5 24
25 23.3 24
12:42 13 20 23.1 24
15 22.7 24
15 22.1 24
20 21.7 24
12:43 14 15 21.0 24
10 20.2 24
10 19.4 24
15 18.8 24
12:44 15 15 18.3 24
10 17.5 24
15 17.1 24
10 16.5 24
12:45 16 10 15.6 24
10 15.0 24
10 14.6 24
10 14.0 24
12:46 17 10 13.8 24
5 13.5 24
5 13.3 24
5 13.1 24
12:47 18 10 12.9 24
10 12.7 24
5 11.9 24
10 11.3 24
12:48 19 5 10.6 24
10 10.4 24
5 10.0 24
5 9.4 24
Adams an Old Castle Company - Lilesville 0400005 13-Apr-08
Natural gas/No. 2 fuel oil-fired
(15 mmBtu/hr max heat input)
Source E030 sand and gravel dryer
(50 tons per hour maximum
VEE Calculation Form capacity)
Actual Minute Minute VE% 6-min avg Count
12:30 1 30
20
30
25
12:31 2 25
25
20
20
12:32 3 25
25
25
30
12:33 4 25
30
30
30
12:34 5 30
30
30
25
12:35 6 30
30
30 23
30 27.1 24
12:36 7 30 27.1 24
30 27.5 24
35 27.7 24
30 27.9 24
12:37 8 30 28.1 24
30 28.3 24
30 28.8 24
30 29.2 24
12:38 9 30 29.4 24
30 29.6 24
25 29.6 24
25 29.4 24
12:39 10 30 29.6 24
35 29.8 24
25 29.6 24
30 29.6 24
12:40 11 30 29.6 24
25 29.4 24
25 29.2 24
30 29.4 24
12:41 12 25 29.2 24
30 29.2 24
30 29.2 24
35 29.4 24
12:42 13 35 29.6 24
30 29.6 24
35 29.6 24
30 29.6 24
12:43 14 25 29.4 24
30 29.4 24
30 29.4 24
30 29.4 24
12:44 15 30 29.4 24
30 29.4 24
35 29.8 24
30 30.0 24
12:45 16 30 30.0 24
30 29.8 24
25 29.8 24
35 30.0 24
12:46 17 35 30.2 24
40 30.8 24
35 31.3 24
30 31.3 24
12:47 18 35 31.7 24
30 31.7 24
35 31.9 24
30 31.7 24
12:48 19 30 31.5 24
30 31.5 24
35 31.5 24
35 31.7 24
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Adams an Old Castle Company -Lilesville,Anson
PHOTOS TAKEN BY J. Cole, 13 April 2017
Excessive V.E. from door and baghouse. Excessive V.E. from door.
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Excessive V.E. from ID fan. Impact of excessive V.E. from plant.