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HomeMy WebLinkAboutAQ_F_0400005_20160616_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: 06/22/2016 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,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 06/16/2016 Inspector's Name Daniel Thoma Inspector's Signature: � '{� Operating Status Operating C Compliance Code Compliance-inspection Action Code FCE Date of Signature: 06 12212,0 6 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(in pounds) 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 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 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. i 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. Mike Thomas conducted the last compliance inspection on 20 Aug. 2015. Current Throughputs for 2015 2015 25,138,000 - 8,176,000 7,442,000 2014 24,015,260 4,574,860 - 662,280 2013 19,429,672 - - 2012 - - - 2011 5,017,514 4) Inspection Summary On 16 June 2016 Heather Carter and I,both of FRO DAQ, met with Kevin Tucker,Plant Manager, and Chris William(Maintenance)we discussed the following: a) Verified the FACFINDER information.Remove Bonsal American under Invoice Contact. b) The facility maintains separate logbooks for each bagfilter.The lead maintenance technician usually performs the inspections,which includes inspections of the bags,blower,ductwork, and observation of visible emissions.The results are all recorded in the logbooks c) Complaints-The facility received a noise complaint from a resident in late 2015,which was resolved by turning the bag houses off when plant was not in production. No other complaints noted. Mr. Tucker led us on a tour of the facility which was operating. The facility keeps the fill access to each of the silos locked so that drivers have to check in before silo filling can take place. According to Mr. Williams 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. We observed the rock and sand conveyor operation and the screening operation(ES03 and ES18). Only ES03 was operating and 0%VE was observed from this source. The sand and gravel dryer, ES30,was operating when we arrived and was restarted for us during our inspection. Rock screen,ES18,is uncontrolled and vents to open air; it not controlled by bagfiliter BH13 as indicated on the permit. It does not appear that BH13 has ever been installed on ES18. Mr. Tucker showed us ES01,ES02 (cement handling operations): Both of these lines operate inside the building and Mr. Tucker stated that the bagfilter,B1101,which controls the Cement handling operation,Line 1, does not vent into the ambient air. It actually vents into the Line 1 Recycled cement silo(SF23),which is controlled by bagfilter, B1323. No VE observed leaving the building. During our tour we identified the silos for lines 1 and 2. There was no VE observed. Mr. Tucker stated the facility will install the two silos and associated bagfilters,permitted in 2015, for specialty cement line sometime in 2017. 5) Emission Sources Permitted Sources Drying Operation,consisting of- Natural as/No.2 fuel oil-fired (15 mmBtu max heat input)sand ES30 and gavel dryer( eat per hour! BH1A Bagfilter maximum capacity) F825quaze feet of filter area) Operating 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 BH23 Bagfilter Operating with 0% VE 1 (156 square feet of filter area) SF24 Fly ash silo,Line 1 BH24 Bagfilter Operating with 0%VE (156 square feet of filter area) SF25 No-mix cement silo,Line 1 BH25 Bagfilter Operating with 0%VE (156 square feet of filter area) Rock and sand bucket conveyor ES03 operation including a rock silo and gH1A Bagfilter a sand silo [(3,825 square feet of filter area)' Operating with 0%VE IF Cement handling operation ESO1 (bagging,weighing,mixing),Line BHOI Bagfilter 1 (3,840 square feet of filter area)',, Operating with 0%VE Production Line 2,consisting oh 40-ton capacity Portland cement Bagfilter SF40 silo,Line 2 BH40 Operating with 0%VE F(156square feet of filter area) iF 80-ton capacity Portland cement SF80 silo Line 2 BV80 Bag filter New Not Installed (264 square feet of filter area) II!� ; 145-ton capacity Portland cement Bagfilter S17145 silo,Line 2 BV 145 (264 square feet of filter area) New-Not Installed _ SF41 Rock silo,Line 2 BH41 Bagfilter Operating with 0%VE �• (156 square feet of filter area) SF42 Sand 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) I SF52 Recycled cement silo,Line 2 BH52 Bagfilter �erating with F (156 square feet of filter area) j ES18 Rock screen from sand,Line 2 BH13 Bagfilter Not Operating (1,200 square feet of filter area) ;F Cement handling operation ES02 (bagging,weighing,mixing),Line i BH02 Bagfilter 2 (1,900 square feet of filter are) Operating with 0%VE 6) Permit Stipulations 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— Previous renewal and inventory were due on 1 Jan 2012. Both were received late, 24 Jan 2012,and a Notice of Deficiency was issued. Next renewal and inventory are due Jan 28, 2017. 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. AA 15A NCAC 2D.0516 SULFUR DIOXIDE CONTROL REQUIREMENT—S02 emissions from the combustion sources shall not exceed 2.3 lbs/mm BTU. APPEARED IN COMPLIANCE—The AP-42 emissions factor for No. 2 fuel oil is 0.507 lbs/mmBtu; natural gas is 0.001 lbs/mmBtu.Facility is only burning natural gas. 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. 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 COMPLLANCE—Mr. Tucker stated that there have been no instances of excess emissions during the past year. Visual observations and records reviewed support that statement. 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 haul roads are gravel/sand, and Mr.Tucker said that he has not received any dust complaints. A.8 15A NCAC 2D.0611 BAGFILTER REQUIREMENTS—Particulate matter emissions shall be controlled as described in the permitted equipment list, The permittee 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 but have not always recorded these inspections in their logbooks due to increased productivity-last entry Sept.2015. This is above and beyond the annual internal inspection requirement. Facility personnel will resume recording monthly inspections and maintenance activities. 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 PMto 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. 7) Non-compliance History Since 2010 Jan. 2012-NOD Failure to renew Air Permit 8) 112R Status This facility neither uses nor stores chemical compounds that require a written risk management plan under the Clean Air Act, Section I I2R. 9) Compliance Statement and Recommendations Adams as Old Castle Company—Lilesville appeared to be in compliance on 16 June 2016. Pink Sheet: Control Device BH 13 not onsite and does not control emissions from ES18 Line 2 Rock screen. Evaluate emission source and control for this process when permit is next touched. Update SF80 description to"80 ton capacity White Portland cement silo,Line 2". Update SF145 description to"145 ton capacity Specialty cement silo,Line 2".