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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