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HomeMy WebLinkAboutAQ_F_0400045_20170418_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: 05/03/2017
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
NAICS: 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
(704)694-2034 (704)694-2034 (704)694-2034
Compliance Data
Comments:
Inspection Date 04/18/2017
Inspector's Name Joshua L.Harris
Inspector's Signature:� ��7 Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: oS/444"7 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP SO2 NOX VOC CO PMIO *HAP
2012 0.7200 --- --- --- 0.2200 0.0610
2007 0.8240 --- --- --- 0.2410 0.0700
*Highest HAP Emitted(inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
03/21/2017 NOV Permit Late Report(excluding ACC) 03/13/2017
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
I. 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
Road,which is just past plant,up to the office on the right.
H. SAFETY: Standard FRO safety gear is required. The inspector should be mindful of vehicular and
heavy equipment traffic.
III. FACILITY/PROCESS DESCRIPTION: Hildreth Ready Mix 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 mixed with
water inside a cement truck. The loadout and silos are controlled by a central dust collector. A second,
unused bagfilter,which was previously used as a dedicated control for one of the silos is still in place,but
it 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"basis.
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.
Through uts:
Operating hours 0900-1700 Monday-Friday w/occasional Saturday
Employees 7 including drivers
Production(cu yd) 2016: 4,147
2015: 7,972.5
2014: 6,000
2013: 2,000
2012:3,397
IV. INSPECTION SUMMARY: On 18 April 2017,Mike Lawyer, FRO DEMLR,and I,Joshua Harris FRO
DAQ,arrived on site to conduct a multimedia inspection of Hildreth Ready Mix,LLC. While entering
the property,we briefly observed a silo being loaded, and noted intermittent visible emissions around the
connections at—5%opacity. These emissions dissipated before reaching the property boundary, and no
other visible emissions were noted,and the facility was otherwise not operating during the inspection. At
the Admin Office,we met Karl Hildreth,Owner,and Chanel Little, Secretary. Mr. Hildreth verified the
FacFinder information, and requested that Ms.Little be listed as the invoice contact.
We reviewed the facility's records,which,while messy,appeared to be complete. Mr. Hildreth described
his methods for maintaining the bagfilter,which appears to be sufficient. Mr.Hildreth stated that he has
not had to change any bags in nearly a decade, and no visible emissions concerns were noted during
previous inspections in which the facility was observed operating.
V. PERMITTED EMISSION SOURCES:
A. One cement mixing weigh hopper and loading operation; and
Not operating
B. Silos for cement and flyash storage.
Cement loading briefly observed with 0%opacity at bagfilter exhaust. Light visible emissions,
—5% opacity, were noted at the connections. No fugitive dust was visible past the property
boundary.
VI. 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: We reminded Mr. Hildreth of this requirement, and reminded him
that his permit will be expiring next year on 30 June 2018. Previously, the facility's emission
inventories, and applications for renewal have been received on time. The facility will be deemed in
non-compliance if the emission inventory and renewal application are not received by 01 April 2018
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)1.61 for P<30 tons/hr,or
E=55 * (P)0"-40 for P>30 tons/hr
APPEARED IN COMPLIANCE: These calculations were made when the facility was permitted,
and the previous permit reviews indicated that thatfacility, when controls are properly maintained
and operated, would not exceed these limits. The facility's particulate emissions are controlled by
bagfilters. Each baezlter appeared to have regular maintenance conducted, and there were no dust
accumulations near their exhaust points which would indicate an operational problem.
C. 15A NCAC 2D .0521 —CONTROL OF VISIBLE EMISSIONS—Visible emissions shall not
exceed 20%opacity.
APPEARED IN COMPLLANCE. The facility was not operating at the time of the inspection,
though we did observe a silo load as we entered, during which light visible emissions, —S%opacity,
were noted around the connections. Mr. Hildreth stated that he does not see visible emissions while
the plant is operating, outside of occasional fugitive emissions at loadout, and that he hasn't received
any recent dust complaints. DAQ has not received any recent complaints pertaining to this facility.
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 COMPLIANCE: There are no indications of arty excess emissions which would
require a notification by the facility. We reminded Mr. Hildreth of the notification requirement.
There have been no recent complaints received by the facility or DAQ.
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 COMPLIANCE. No fugitive dust concerns at the property boundaries were noted
during the inspection, though the facility is located just off the street. The facility was not operating
at the time of the inspection, but we were able to briefly observe a silo load. Brief, light visible
emissions were noted at the connections, and no dust was visible past the property boundary. There
have been dust complaints in the past associated with the truck loadout, but none have been received
by DAQ in the past two years.
F. 15A NCAC 2D.0611—FABRIC FILTER REQUIREMENT—Particulate emissions controlled by
fabric filters; annual internal inspections;record keeping.
APPEARED IN COMPLIANCE. Mr. Hildreth performs the maintenance himse f and described his
method for cleaning and inspecting the bagfilter. 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's production log has an entry on 28 January 2017, which states
simply that the bagfilter was cleaned.
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.
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 4,147 cubic yards in 2016 Mr. Hildreth stated that
there have been no changes to the facility, and we reminded him of the notification requirement. 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.
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
throughput, and the annual throughput, 4,147 cubic yards in 2016, is also much less than the 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 was much less than this limit,
therefore compliance is indicated.
VH. INSIGNIFICANT ACTIVITIES:
I-1 2Q ,0102(c)(2)(E)(i) No Yes
Sand and Aggregate Handling
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.
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 COMPLLANCE with their current air permit.
PINK SHEET ADDITIONS:
- None.
/jlh