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HomeMy WebLinkAboutAQ_F_0400005_20111130_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Bonsal American NC Facility ID 0400005 Inspection Report County/FIPS: Anson/007 Date: 12/01/2011 Facility Data Compliance Data Bonsal American Inspection Date 11/30/2011 351 Hailey's Ferry Road Inspector's Name Cindy Grimes Lilesville,NC 28091 Operating Status Operating Lat: 34d 57.5360m Long: 79d 57.4490m Compliance Code Compliance-inspection SIC: 3272/Concrete Products,Nec Action Code FCE NAILS: 32739/Other Concrete Product Manufacturing On-Site Inspection Result Compliance Contact Data Permit Data Facility Contact Authorized Contact Technical Contact permit 01759/R19 Charles Knight Jeff Horne Ken Brown Issued 10/3/2007 Safety,Health,and Plant Manager EHS Director Expires 3o 1/2012 Environmental Rep. (704)848-4141 x13 (704)821-1915 Classification Synthetic Minor Permit Status Active (704)848-4141 Inspector's Signat�: � Comments: Date of Signature: tZ_' '117 oti , MACT/GACT Applicability: None(Not subject to 4Z,Stationary Reciprocating Internal Combustion Engines,as there are no emergency generators on site). 1) Location Bonsal American is located at 351 Hailey's Ferry Road, outside of Lilesville,NC, Anson County. Directions From FRO,take Hwy 401 South to Wagram.Turn right onto Old Wire Road(Hwy 144)and go— 11 '/ miles to Laurel Hill. Turn right onto US 74 West and continue for—25 mites until you enter Anson County,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.2 mile,and then just before the railroad tracks,take a left onto facility's dirt drive. Main office is thru parking lot and to the right. Safety Considerations: Standard DAQ safety equipment,including vest. Watch for forklifts and truck traffic throughout the whole facility during inspection. 2) Facility and Process Description W R. Bonsal, Inc. 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.This facility is permitted under Air Permit No. 1759R19,effective from 3 October 2007 until 31 March 2012. Cindy Grimes conducted the last compliance inspection on 24 August 2011. 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. a) Current Throughputs for 2010 Employees: 24 (including drivers)(21 in 2009) Hours: 6AM—2:30PM Mon-Fri,40 hrs/wk, 52 wks/yr(same in 2009) Material received: Portland Cement 24,015,260 lbs (23,156,750 lbs in 2009) Masonry 4,574,860 (4,136,754 lbs in 2009) Fly Ash 662,280 (4,056,782 lbs in 2009) Units Produced: 2,228,540 Bags (1,967,691 Bags in 2009) b) Permitted Sources _ EmissionF Emission Source Control Control System Source ID Description System ID Description Drying Operation,consisting of: ES30 Natural gas/No.2 fuel oil-fired(15 BH1A Bagfilter(3,825 square feet of filter area) mmBtu max heat input)sand and gravel dryer(50 tons per hour maximum capacity) i Production Line 1,consisting of: SF22 Portland cement silo,Line 1 BH22 Bagfilter(156 square feet of filter area) SF23 lRecycled cement silo, Line 1 BH23 Bagfilter(156 square feet of filter area) —� SF24 Fly ash silo,Line 1 I BH24 Bagfilter(156 square feet of filter area) SF25 INomix cement silo,Line 1 BH25 jBagfilter(156 square feet of filter area) ES03 Rock and sand bucket conveyor BH1A Bagfilter(3,825 square feet of filter area) operation including a rock silo and a sand silo ESO1 [Ceiinneii,,thandling operation(bagging, BHO1 Bagfilter(3,840 square feet of filter area) eghg,mixing),Line 1 Production Line 2,consisting of: j — i SF40 Portland cement silo,Line 2 1 BH40 jBagfilter(156 square feet of filter area) SF41 IRock silo,Line 2 BH41 Bagfilter(156 square feet of filter area) I SF42 ISand silo split,Line 2 BH42 Bagfilter(156 square feet of filter area) SF43 IFly ash silo,Lin_ e 2 BH43 113agfilter(156 square feet of filter area) SF44 Type S cement silo,Line 2 BH44 Bagfilter(156 square feet of filter area) SF52 Recycled cement silo,Line 2 BH52 (Bagfilter(156 square feet of filter area) ES IS Rock screen from sand, Line 2 BH 13 1Bagfilter(1,200 square feet of filter area) — -- ---- ES02 Cement handling operation(bagging, BH02 113aafitter(1,900 square feet of filter are) j weighing,mixing),Line 2- 3) Inspection Conference On 30 November 2011,I(Cindy Grimes)met with Jeff Horne(Plant Manager). Charles Knight,the Facility Contact,was out of town and not available.This was a pre-arranged inspection,as it was for perm it renewal. Mr. Horne and I discussed the following: a) Verified the FACFINDER information.Mr.Horne asked to make him the Authorized Contact, as Frank Ketchum is no longer with the company. I will change this information in I-Beam. b) There have been no changes since the last compliance inspection. Mr. Horne told me there have been no problems with any of the permitted equipment. c) The company decided to have an outside consultant complete the application forms and emissions inventory. I reminded Mr.Horne that everything needs to be in our office by 3 January 2012. d) I inspected the logbooks, of which separate ones are kept for each bagfilter. The lead maintenance technician(Kevin Cassidy)or Mr.Knight usually performs the inspections,which includes inspections of the bags, blower, ductwork, and observation of visible emissions.The results are all noted in the logbooks. These inspections used to be done weekly but are now done—every 3 weeks. The last general inspection was on 16 November 2011.There is also an annual inspection done on the system, usually toward the beginning of each year.The 2011 inspection was performed in January. 4) Inspection Summary Mr.Horne led me on an inspection of the facility,which was not operating at the time. Production has been very slow in November, so employees were doing a thorough cleaning of all systems, as well as the bagging warehouse. The results are as follows: a) There was no unloading of products that occurred during the inspection. Drivers are told to unload at 10-15 psi,with their trucks being set at the maximum pressure of 15 psi before a relief valve on the trucks is kicked off. b) SF-22,23,24,25,40,41,42,43,44,and 52(all silos): I observed no excess build up of materials on any of the silos,which might indicate any compromises. SF-22,the Portland cement silo, was operating, so as to "blow out"excess dust that had accumulated.VE was— 15%. Mr. Horne said that the other silos had already been cleaned out. c) ES-03 (rock& sand conveyor operation),ES-18(rock screen from sand): I observed no compromises or problems with any of the conveyors and screens. d) ES-01,ES-02 (cement handling operations): Both of these lines operate inside a warehouse, and employees were sweeping and cleaning the floors during the inspection. I observed no problems. e) ES-30 (sand and gravel dryer): Even though this dryer is old, it appears to function well. The input temperature range for the sand is usually between 300-325 degrees F, and for the gravel, 225-250 degrees F. I observed no obvious problems,and since it was not operating, VE was 0%. There is a magnehelic manometer on the dryer to record the various drops of pressure within the bag house. Maintenance checks the readings regularly and then records them into the logbooks. f) I saw no excess dust from any trucks entering or leaving the facility. 5) Permit Stipulations a) A.3 213 .0515 PARTICULATE CONTROL REQUIREMENT—Particulate matter em issions fi-om sources shall not exceed the allowable rates. Compliance Indicated—Latest permit review indicates compliance. b) AA 2D .0516 SULFUR DIOXIDE CONTROL REQUIREMENT—S02 emissions from the combustion sources shall not exceed 2.3 Ibs/mm BTU. Compliance Indicated—The AP-42 emissions factor for No.2 fuel oil is 0.507 lbs/nunBtu;natural gas is 0.001 Ibs/mmBtu. Facility is only burning natural gas at this time. c) A.5 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENT—Visible emissions from the emission sources shall not exceed 20% opacity. Compliance Indicated—All visible emissions observed were<20% in opacity. d) A.7 2D .0540 FUGITIVE CONTROL REQUIREMENT-The Perm ittee steal l not allow fugitive non-process dust emissions to contribute to substantive complaints. Compliance Indicated—I saw no excess fugitive dust emissions during my inspection.The haul roads are gravel/sand, and Mr. Horne said that he has not received any complaints. He uses water from a watering truck if dust becomes a problem during a dry spell. e) A.8 2D .0611 BAGFILTER REQUIREMENTS—Particulate matter emissions shall be controlled by the permitted equipment list,with periodic/annual inspections performed and records kept in a logbook. Compliance Indicated—Separate logbooks are kept for each bagfilter, and regular and annual inspection records are kept current. 6) Reporting Requirements There are no reporting requirements for this facility in their current permit. 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 a) 9 November 2005—NOV/NRE for B6,Improper Operation and Maintenance and 2D.0535, Failure to Report Malfunction. b) 30 September 2003 —NOV/NRE for 2D .0521,Excessive Visible Emissions. c) 6 September 2000—NOV/NRE for Operating Without an Air Permit and B6, Improper Operation and Maintenance d) 15 June 1999 -Warning Letter, excess dust from play sand silo. 9) Comments and Compliance Statement During next year's inspection, inspector should take time and review new permit with contact. Note: The question had come up in the past concerning if this facility is subject to NSPS Subpart UUU (Standards of Performance for Calciners and Dryers in Mineral Industries).In 2010,Robert Hayden and Cindy Grimes called Frank Ketchum (facility's Authorized Contact)to get information concerning the rotary sand dryer.The dryer here was installed in the 1950's,thus predating the requirements of this subpart(installation date must be after 23 April 1986 to be subject). Bonsal American appeared to be in compliance on 30 November 2011. /clg