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HomeMy WebLinkAboutAQ_F_0400047_20120612_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY B.V.Hedrick Gravel and Sand Company NC Facility ID 0400047 Inspection Report County/FIPS: Anson/007 Date: 06/13/2012 Facility Data Compliance Data B.V.Hedrick Gravel and Sand Company Inspection Date 06/12/2012 B.V.Hedrick Gravel Plant Rd. &Hwy 74 E Inspector's Name Cindy Grimes Lilesville,NC 28091 Operating Status Operating Lat: 34d 56.7302m Long:79d 55.8806m Compliance Code Compliance-inspection SIC: 1442/Construction Sand And Gravel Action Code FCE NAICS: 212321 /Construction Sand and Gravel Mining On-Site Inspection Result Compliance Contact Data Permit Data Facility Contact Authorized Contact Technical Contact permit 09572/R03 Timothy Jones Jeffrey Goodman Jason Conner Issued 10/12/2010 Superintendent President Environmental Director Expires 9/30/2015 (704)848-4165 (828)277-7030 (828)686-3844 Classification Synthetic Minor Permit Status Active Inspector's Signature: �, \ �� Comments: Date of Signature: C I ti (ZO MACT/GACT Applicability: Sithject to: MACT Subpart ZZZZ—RICE—Reciprocating Internal Combustion Engines—facility is an area source for HAPs and has four diesel engines (CI ICE<500HP)on site.Units T-G10 and XQ60 are "existing" units under this regulation (before 12 June 2006) and will be required to comply as of May 3,2013.Units C50-G4 and Aztec G-1 are"new" units (on/after 12 June 2006),will be required to comply as of May 3,2013 and also are currently required to comply with the requirements of NSPS Subpart HII. 1) Location B.V. Hedrick Gravel and Sand is located at 403 B.V. Hedrick Gravel Plant Road, off Hwy 74 East near Lilesville,NC, in Anson County. Directions From FRO,take Hwy 401 South to Wagram. Turn right at Old Wire Road (Hwy144) and go— 11 '/2 miles to Laurel Hill.Turn right at Hwy 74 and go west—30 miles toward Lilesville;you'll pass Rockingham and then the Pee Dee River. Look for Gravel Plant Road on the left about 5 'h miles after crossing the river. There will be a B.V.Hedrick Gravel and Sand Company sign at entrance of road. Turn left, follow drive,and after crossing the railroad tracks,you'll see the scale house to the right at entrance to plant. Check in at scale house and ask for Plant Superintendant Tim Jones. Safety considerations: Standard DAQ safety equipment,as well as safety vest. Watch for trains at the railroad tracks just before entering property,as well as large trucks and loaders while on site. 2) Facility and General Description B.V. Hedrick Gravel and Sand Company is a mining facility that primarily produces sand for commercial use and is permitted for crushing gravel. This facility is permitted under Air Permit No. 095721103, effective from 12 October 2010 until 30 September 2015. Cindy Grimes conducted the last inspection on 20 April 2011. This facility is a quarry which extracts mainly granite from the earth. The granite and crushed stone products are loosened by drilling and blasting,and then are loaded by power shovel or front-end loader into large haul trucks that transport the material to the processing operations. Primary operations include a jaw, which is used for initial crusher reduction,and a series of conveyors. This crusher product is next fed through a grizzly feeder for undersize material, and then is discharged onto a conveyor, where it goes through more screening processes, until it is conveyed to a surge pile for temporary storage or sold as coarse aggregate. The finest product is sold to customers,who then bag and sell the"sand", which is used mainly in small aquariums. At the present time(June 2012),this facility is operating the Telesmith 38SBS Portable Crushing Plant, which consists of one cone crusher unit, one horizontal screen, one feed conveyor, one closed conveyor, one underscreen fines conveyor and two discharge conveyors.The generators currently being used with this operation are the T-G10 (365 HP CAT diesel engine)and the XQ-60 (100 HP CAT diesel engine). The C50 Portable Crushing Unit was only used for 5 months in 2011 and consists of one jaw, one grizzly feeder,one discharge conveyor and one side conveyor,with the generator used being the G-4 (350 HP CAT diesel engine). The Aztec Direct Feed Unit was only used for 3 months in 2011 and consists of one screen, one belt feeder and five conveyors,with the generator being the Aztec G-1 (125 HP John Deere diesel engine). The Telesmith T-300 Portable Plant is new on site(February 2012), is only being used by BV Hedrick for testing purposes(to determine if the company wants to purchase it in the future), and it started up on 4 April 2012. It is not required to be added to the facility's permit at this time. It consists of one cone crusher, one screen, three conveyors and one P-SCR generator(1081 HP CAT diesel engine). a) Permitted Sources y ' xi. i § M `xion � �� E rss� urce Conrol Confrlv ol System Descrin - stem ID 3l �Descri tion�kF Quarr-y.Equipment q Crushers(NSPS) Crushing and Feeding Operations WS Wet suppression water spray system Screens(NSPS) Screening Operations WS Wet suppression water Fspray system Conveyors(NSPS) Conveying Operations WS Wet suppression water spray system Power Generation,Vnits Aztec G-1 (NESHAP), C50 G4(NESHAP), Diesel-Fired Generators N/A N/A T-G 10(NSPS,NESHAP), XQ60(NSPS,NESHAP) b) Throughput for 2011 Tons Generator Hours NOx Emissions Production of March-November 69,871 1290.5 4.59 tons crushed stone: (2010) (27,501) (436) (.53 tons) Employees: 3 (same in 2010) Hours: variable(between 7AM and 6PM)(same in 2010) 3) Inspection Conference On 12 June 2012, I(Cindy Grimes)arrived at this facility. Tim Jones, Superintendent and Facility Contact here,was not immediately available, so I initially looked thru the DAQ binder-logbook,made available to me at the scale house, and I learned the following: a) Verified the FACFINDER information;there have been no changes. b) Initial production began in November 2009, after performing two blasts, but then only ran for—2 months, due to the poor economy. They started back up in September 2010 and have run on and off since.The facility has blasted several more times in 2011 and 2012 since the initial blasts in 2009. c) I went through the logbook and noted the following within it: i) The required fugitive dust control plan and log was submitted to and approved by DAQ in October 2009.The log has daily entries of mechanical water suppression for fugitive dust, as well as dates it had rained(when suppression was not needed). The log was up to date. ii) Daily tons of crushed stone, as well as monthly total(including 0 tons for all the inactive days). iii) Daily number of unit hours each permitted generator ran, as well as the total monthly NOx emissions for each. The log contains a separate section for each individual generator, noting the hours ran,tons of stone crushed while operating, and any maintenance performed on the unit. iv)The plot plan showing the boundary distance(the shortest distance between any non-road source and the property boundary here) is 441 feet. v) The equipment list and scheme,which contains ID numbers, size/capacity, manufacturing date, and any performance test dates.The Aztec G-1,T-G10,XQ 60 and C50 G4 are the generators currently running. The C50 G4 started up on 14 June 2011. vi) The most recent spray nozzle inspections on all of the plants were done in May 2012; no corrective actions were needed, as the nozzles were working properly. d) This facility has been using ultra low sulfur diesel fuel(< .0015% S) since 1 October 2010, when it was required by NSPS to do so.I verified this by observing several of the latest fuel bills of lading. e) A VE test(Method 9)was performed on 4 November 2010 for the Telesmith 38SBS Portable Plant and reviewed and approved by DAQ on 17 Dec 2010. The latest VE test was performed on 28 September 2011 for the C50 Portable Plant and approved by DAQ on 21 October 2011. Another VE test is scheduled to be performed on 16 August 2012 for the T-300 Telesmith Portable Plant. 4) Inspection Summary(facility was not operating during inspection;the Telesmith 38SBS Plant had a belt that had broken the previous day and it had not yet been replaced, and neither the C50 nor the T-300 Plants were operating; plant foreman Sam Timmons drove me thru the quarry for the inspection) a) Crushers,Screens,Conveyors: I observed all of this equipment on site, as wel l as the water spray points on each conveyor. All prior inspections of operating crushing units have been at or below 5% VE;the wet suppression here is good. b) 125 HP Diesel Generator(Astee G-1): This engine was manufactured in 2008, on site, and ran a total of 246 hours in 2011. c) 350 HP Diesel Generator(C50 G4): This engine was manufactured in 2009, on site, and ran for 184 hours in 2011. I d) 365HP Diesel Engine(T-G10): This engine was manufactured in 2002, on site, and ran for 433'/4 hours in 2011. e) 10011P CAT Generator(XQ 60): This engine was manufactured in 2001, on site and ran for 427'/4 hours in 2011. f) Roads: All roads on site were damp from the facility's water truck,which was continually spraying on site during my inspection. I observed no fugitive dust problems. There had also been rain the previous day. Note: All generators have non-resettable hour meters. 5) Permit Stipulations: a) A.4 2D .0501(c) PRODUCTIONRATE LIMITATION—Production shall not exceed the Maximum Allowable Production Rate of 12,000 tons/day and 4,250,000 tons/year, with a boundary distance b/t 300 and 450 feet; records shall be kept indicating so(indicating daily and monthly quantity). Compliance Indicated—I viewed the logbooks and the highest production of crushed stone in 2011 was 800 tons per day and 14,800 tons per month(in July 2011). The facility ran off and on during 2011; it maintains a 12-month rolling production rate in the logbook. The annual production will be far below the production maximum capacity.Boundary distance is 441 ft. b) A.5 2D .0501(c) EQUIPMENT REPORTING—An equipment list shall be kept on site, showing compliance with all permitted requirements.The Permittee must notify FRO if equipment changes are made. Compliance Indicated—A diagram of the permitted equipment list is kept on site in a DAQ binder, as well as the permitted equipment yet to be brought in, showing the rated capacities,ID numbers, size, and dates.I viewed this list, and it meets all requirements of this facility's permit. c) A.6 2D .0510 PARTICULATE CONTROL REQUIREMENT—As required by"Particulates from Sand, Gravel, or Crushed Stone Operations",this operation shall take measures to reduce particulate matter from becoming airborne so as to prevent exceeding the ambient air quality standards beyond the property line for PM; emissions from all operating equipment shall be controlled. Compliance Indicated—The crushers, screens, and conveyors are all controlled by a wet suppression water spray system.I saw no particulate matter/dust beyond the property boundaries, and there have been no complaints regarding dust. d) A.7 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENT-Visible emissions from sources post 1 July 1971 shall not be more than 20%opacity. Compliance Indicated—Since facility was not operating,I saw 0%VE. e) A.8 2D .0524 NEW SOURCE PERFORMANCE STANDARDS(for the processing equipment) - The Permittee shall comply with all NSPS reporting,testing, and recordkeeping requirements as promulgated in 40 CFR 60, Subpart 000. Compliance Indicated—DAQ FRO received notification of initial start up of its equipment on 3 December 2009(start-up date was 18 November 2009,but facility did not achieve maximum production rate until September 2010); facility keeps logbook on site showing inspections of the wet suppression system;NSPS Performance Testing(with the pollutant being visible emissions) was achieved on 4 November 2010, 28 September 2011,and another Method 9 test is scheduled for 16 August 2012 (all tests were compliant with notification,performance,and submission). f) A.9 2D .0524 NEW SOURCE PERFORMANCE STANDARDS,Subpart IIII(for the Compression Ignition Internal Combustion Engines Generators[Aztec G-I and C50-G41)—The Permittee shall comply with all NSPS reporting,testing, and requirements as promulgated in 40 CFR 60 Subpart 11I1; applicable sources are the generators constructed after 1 April 2006; compliance includes: (1) purchase of a 2007 model or later CI ICE and ensuring that it is emissions-compliant and keeping records of all manufacturing data(indicating compliance); (2) diesel fuel used shall be < .05% S through 1 October 2010 and<.0015% S thereafter; (3)installation of a non-resettable hour meter;(4)record hours of engine operation; (5)submit a semi-annual report that includes monthly and 12-month operation hours. Compliance Indicated—(1)Manufacture date of Astec G-1 is 2008 and of C50-G4 is 2009, of which manufacturer's information indicates compliance of EPA emission standards; (2)the fuel delivery bills of lading showed that the diesel fuel purchased was<.05% S thru Sept'10 and <.0015% S diesel fuel since then; (3)The sources all have non-resettable hour meters;(4)I reviewed the logbook that had entries for the hours of operation for the Astec G-1 (C50-G4 has not operated yet); (5)facility's latest semiannual report due 30 January of this year was submitted on time and compliant. g) A.11 2D .0540(e)(1) FUGITIVE DUST CONTROL PLAN—The Permittee shall have a DAQ approved written fugitive dust control plan to minimize dust emissions from fugitive sources. Compliance Indicated—Facility submitted a fugitive dust control plan that was approved by DAQ on 16 October 2009. I observed it on site, and I saw no excess dust emissions during my inspection. The facility appears to be following the plan. h) A.12 2D .0540 FUGITIVE DUST CONTROL REQUIREMENT—The Permittee shall not cause or allow fugitive dust emissions to contribute to complaints or excess visible emissions beyond the property. Compliance Indicated—I saw no excess fugitive dust emissions during my inspection. i) A.13 2D .1111,40 CFR 63, Subpart ZZZZ NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR STA TIONAR YRECIPROCA TING INTERNAL COMBUSTION ENGINES—Applicable to new sources(if commenced construction on or after 12 June 2006); installed generators must have manufacturing data showing emissions compliance, and facility must keep records of maintenance and operating hours; the Permittee shall comply with all notification, testing,and monitoring requirements; compliance date would be upon start-up. Compliance Indicated—All four of the current diesel engines on site are applicable to this regulation. Units T-G10 and XQ 60 are"existing"units(manufactured on or prior to 12 June 2006), and they will be required to comply with Subpart ZZZZ as of 3 May 2013. Units C50 G4 and Aztec G-1 are"new" units,required to comply with Subpart ZZZZ as of 3 May 2013 (as well as NSPS Subpart 1I1I now). j) A.14 2Q .0315 LIMITATION TO AVOID 1 SA NCAC 2Q.0501 FOR SYNTHETIC MINOR FACILITIES—Facility-wide NOx emissions shall be less than 100 tons per each 12 month period, and facility shall keep records indicating so. Compliance Indicated—Facility keeps a logbook with monthly NOx emission entries for all generators operating. 2011 total annual NOx emissions were 4.59 tons, which is far below 100 tons. 6) Reporting Requirements Semiannual report is due 30 January and 30 July of each year showing compliance of 2D .0524 NSPS, 40 CFR 60 Subpart IIII,for the Cl ICE. 7) 112R Status This facility neither uses nor stores chemical compounds that require a written risk management plan under the Clean Air Act, Section 112R. 8) DAQ Compliance History There have been no prior DAQ violations in this facility's permitted history. 9) Comments and Compliance Statement This facility appears to be complying with all DAQ stipulations as to date. The superintendent, Tim Jones, seems to be keeping the proper documents and is aware of the compliance for air quality. The Authorized Contact,Jason Conner,appears to be providing DAQ FRO with the proper notifications per permit stipulations as well as submitting the proper protocols for future Method 9 tests. B.V. Hedrick Gravel& Sand Company appeared to be in compliance on 12 June 2012. Compliance inspector should verify the below GACT 4Z requirements starting 3 May 2013: A) GACT 4Z Reciprocating Internal Combustion Engines (RICE) Requirements for Source T-G10 (existing, pre 6/12/2006, stationary non-emergency engine, >300HP but < 500HP, at an area source).Requirements include: i) Compliance Date: 3 May 2013 ii) Emission Limits: 63.6603 Table 2d - Minimize idling and change oil and filter every 1000 hrs or annual(whichever comes first) iii) Operating Limits: No requirements iv) Fuel Requirements: 63.6604 -Fuel must have <15 ppm S, cetane >40 or aromatic content <35%V v) Performance Tests: 63.6612/.6620 - Performed within 180 days after compliance date; performance testing at 90%,with three 1-hour runs vi) Maintenance: 63.6625(g) - Operate per manufacture specs with crank case I & M and filter changes; 63.6625(h)-Limit idle to 30 minutes,which after 30 minutes,emission standards begin vii) Initial Compliance: 63.6630/Table 5: Limit Formaldehyde and CO concentration in exhaust and reduce Formaldehyde and CO emissions viii) Continuous Compliance: 63.6605/.6640 - General duty to minimize emissions; report any deviations from emission limits;non-income producing operation limited to 50 hrs/yr ix) Notifications: 63.6645 — Initial notification with statement and justification; for compliance demonstration, submit Notification of Compliance Status 60 days after test x) Recordkeeping: 63.6655 - Record any malfunctions; maintain control equipment and/or monitors. xi) Reporting: 63.6650 — Compliance report if any deviations from emissions or operating limitations xii) General Provisions: Yes(see 40 CFR Part 63) B) GACT 4Z Reciprocating Internal Combustion Engines (RICE) Requirements for Source XQ60 (existing, pre 6/12/2006, stationary non-emergency engine, <30011P, at an area source). Requirements include: i) Compliance Date: 3 May 2013 ii) Emission Limits: 63.6603 Table 2d - Minimize idling and change oil and filter every 1000 hrs or annual(whichever comes first) iii) Operating Limits: No requirements iv) Fuel Requirements:None v) Performance Tests:No requirements vi) Maintenance: 63.6625(e)- Operate per manufacture specs or develop maintenance plan to minimize emissions; 63.6625(h)- Limit idle to 30 minutes, which after 30 minutes, emission standards begin; 63.6625(i)—can use oil analysis to extend oil change schedule (default is earlier of 500 hrs or annually) vii) Initial Compliance:No requirements viii) Continuous Compliance: 63.6605/.6640: General duty to minimize emissions; report any deviations from emission limits;non-income producing operation limited to 50 hrs/yr ix) Notifications: No requirements x) Recordkeeping: 63.6655 - Record any malfunctions; maintain control equipment and/or monitors. xi) Reporting:No requirements xiii) General Provisions: Yes(see 40 CFR Part 63) C) GACT 4Z Reciprocating Internal Combustion Engines (RICE) Requirements for Sources Aztec G-1 and C50 G4 (new, post 6/12/2006, stationary non-emergency engines <50011P, at an area source).Requirements include: i) Engines are subject to 40 CFR part 60, subpart IIII(CI NSPS). See Stipulation A.9 2D .0524 Below is the current equipment which is on site at this facility, as of 12 June 2012: Telesmith 38SBS Portable Plant (Method 9 VE test completed 11/4/2010) T-PCr3: 38SBS Cone T-PS2: 6 x 20 Horizontal Screen T-F3: 30"Feed Conveyor T-PC1: 30"Closed-circuit Conveyor T-PC2: 42"Underscreen Fines Conveyor T-PC3: 30"Discharge Conveyor T-PC4: 30"Discharge Conveyor T-G10: 365HP CAT Diesel Engine XQ-60: 100HP CAT generator C50 Portable Crushing Unit (Method 9VE test completed on 9/28/2011) J-1: 50"x 26"Jaw F-2: 46.5"x 169"Grizzly Feeder C-3: 42"Discharge Conveyor C-4 26" Side Conveyor G-4: 350 Cat C9 Engine Telesmith T-300 Portable Plant (Method 9 VE test to be completed on 8/16/2012) T300-1: 400 HP Cone T300-2: 7' x 20' 31) Screen T300-3: 36"Conveyor T3004: 36"Conveyor T300-5: 42"Conveyor T300-6: 30"Conveyor T3 00-7: CAT 725 KWA 081 HP Unit P-SCR: 80 HP Unit /clg