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HomeMy WebLinkAboutAQ_F_0400037_20201208_PRMT_PmtRvw NORTH CAROLINA DIVISION OF Region: Fayetteville Regional Office AIR QUALITY County: Anson Application Review NC Facility ID: 0400037 Inspector's Name: Mike Turner Issue Date: 12/14/2020 Date of Last Inspection: 09/04/2020 Com liance Code: 3 /Compliance- inspection Facility Data Permit Applicability(this application only) Applicant(Facility's Name): The Quikrete Companies- Peachland Plant SIP: NSPS: Facility Address: NESHAP: The Quikrete Companies- Peachland Plant PSD: 13471 Highway 74 West PSD Avoidance: Peachland,NC 28133 NC Toxics: I I2(r): SIC: 3272/Concrete Products,Nec Other: NAICS: 32739/Other Concrete Product Manufacturing MODIFICATION Facility Classification: Before: Synthetic Minor After: Synthetic Minor Fee Classification: Before: Synthetic Minor After: Synthetic Minor Contact Data Application Data Facility Contact Authorized Contact Technical Contact Application Number: 0400037.20B Leroy Bean Leroy Bean Braden Keiger Date Received: 12/01/2020 Plant Manager Plant Manager Application Type: Modification (704)272-7677 (704)272-7677 (678)234-3344 Application Schedule: State P O Box 99 P O Box 99 500 Marathon Parkway Existing Permit Data Peachland,NC 28133 Peachland,NC 28133 Lawrenceville,GA 30046 Existing Permit Number: 06907/R09 Existing Permit Issue Date: 11/25/2014 Existing Permit Expiration Date: 10/31/2022 Review Engineer: Gregory Reeves Comments/Recommendations: Issue 06907/R10 Review Engineer' Signature: Date: Permit Issue Date: 12/14/2020 Permit Expiration Date: 10/31/2022 1. Purpose of Application: The Quikrete Companies—Peachland Plant is requesting modification of their air permit to include 3 new fabric filter controls,which will replace three existing fabric filters. See section 4 below for details. The facility is classified as Synthetic Minor for PM,o. The application did not contain any confidential information. There is one facility file"Pink Sheet" item to address in this permit revision. A 02Q .0318 Notification was submitted in August 2016 for replacement of CD-12 with a new 250 square foot filter area bagfilter. This change will be incorporated into this permit modification. The facility contact for the permit application is Braden Krieger(678-234-3344). r The Quikrete Companies—Peachland Plant Permit R10 Review Page 2 of 6 2. Application Chronology: 10/26/20 FRO received a 02Q .0318 Notification Forms, signed by the Maintenance Manager, David Snyder,for replacement of three bagfilters at the facility. 10/28/20 Greg Reeves spoke with Mr. Snyder by phone. Mr. Snyder stated that the three bagfilters in question had already been replaced and were currently in operation. Mr. Snyder was informed that since the devices had already been installed and placed into operation,they could not qualify under the 02Q .0318 Notification process and that a permit application would be required,to include$400 in fees. 10/30/20 A letter was sent to the facility noting that the changes requested in the 02Q .0318 Notification form did not meet the requirements,and that a permit application would be required. 10/30/20 NOD issued for altering air emission sources without first obtaining a permit. 12/01/20 FRO received the permit application package. Several application forms were not completed correctly,and the facility was requested to resubmit the forms. Electronic payment'of the permit application processing fees was requested. The application was deemed incomplete for processing. PERMIT APPLICATION CLOCK OFF 12/07/20 FRO received the amended permit application forms. PERMIT APPLICATION CLOCK ON 12/07/20 Payment for the permit application processing fees was made electronically. 12/09/20 FRO sent the facility a letter acknowledging receipt of the permit package. 3. Process Description Quikrete is a dry concrete mixing and bagging operation. The facility receives cement and mortar in powder form and stores these materials in silos. The facility dries sand and gravel in a rotary dryer and stores these materials in silos. The materials are metered out of the silos and mixed prior to packaging in 50 pound bags or large bulk bags. Particulate emissions from the silos,the dryer and the mixing/packaging operation are controlled by a total of seven bagfilters. 4. New Equipment/Change in Emissions and Regulatory Requirements,and PE Review Requirements: The modifications requested in this permit application are as follows: • Replacement of existing 125 sq ft filter area bagfilter(ID No.CD-9)with two new 145 sq ft filter area bagfilters(ID Nos.CD-15 and CD-16). CD-15 is to be associated with the cement split silo(ID No. ES-9S 1),and CD-16 is to be associated with the fly ash split silo (ID No. ES-9S2); and • Replacement of existing 125 sq ft filter area bagfilter(ID No. CD-11)with anew 145 sq ft filter area bagfilter(ID No.CD-17). This control is associated with the cement/fly ash silo The Quikrete Companies—Peachland Plant Permit R10 Review Page 3 of 6 (ID No. ES-1 1 S). In addition to the two changes noted above,a previous replacement of CD-12 with a 250 sq ft filter area bagfilter will be incorporated into this permit modification. The replacement of this control device was approved via a 02Q .0318 Notification in August 2016. No change will be made to the control device ID number. The updated 02D .0521 "Visible Emissions Control Requirement"permit condition has been incorporated into the permit. The updated 02D .0611 "Fabric Filter Requirements"condition has been incorporated into the permit. The 02D .1806 "Control and Prohibition of Odorous Emissions" permit condition has been incorporated into the permit. There are no changes in emissions expected due to these changes. These changes do not require a review and certification by a Professional Engineer under 02Q .0112. 5. Permitted Emission Sources and Controls Emission Emission Source Control Control System Source Description System ID Description ID One LPG-fired rotary dryer Bagfilter(3,240 square feet filter ES-1 140 tons per hour maximum throughput CD-8 20 mmBtu/hr maximum heat input area) ES-4 Cement packaging operation CD-2 Bagfilter(2,403 square feet filter area) ES-6 One Sand silo CD-14 Bagfilter(125 square feet filter area) ES-9S 1 One compartment of split silo CD-15 Bagfilter(145 square feet filter area) (cement or fl ash) ES-9S2 One compartment of split silo CD-16 Bagfilter(145 square feet filter area) (cement or fl ash) E S-11 S One compartment of split silo C D-17 Bagfilter(145 square feet filter area) (cement or fl ash) ES-12S One compartment of split silo CD-12 Bagfilter(250 square feet filter area) (cement or fl ash) ES-13S Two sand/aggregate silos CD-13 Bagfilter(250 square feet filter area)] 6. NSPS,NESHAP,PSD,Attainment Status, and 112(r) • NSPS—Does not apply to this facility. The rotary dryer(ID No. ES-1)is not subject to NSPS Subpart UUU—"Standards of Performance for Calciners and Dryers in Mineral Industries," since the dryer was manufactured prior to April 23, 1986(built in August 1978). • NESHAP—There are no current NESHAP regulations that apply to this facility The Quikrete Companies-Peachland Plant Permit R10 Review Page 4 of 6 • PSD-Does not apply to this facility. Anson County has not triggered PSD minor source increment tracking. • Attainment Status-Anson County is in attainment. • 112 (r)-The facility does not store any of the subject materials above the 1 12r threshold quantities and is not required to maintain a written Risk Management Plan (RMP). 7. Facility Emissions Review(excerpted from the review of the permi t renewal R09 review dated 11/25/14). Note that no emission increases are expected due to the changes in this permit application. 2013 Actual Potential Emissions Potential Emissions Pollutant Emissions After Controls Before Controls tons/ r) tons/ r tons/ r PM 1.87 5.57 5572.99 PM 10 0.74 2.25 2245.60 PM,s 0.09 0.67 0.67 CO 0.97 7.18 7.18 NOx 0.84 12.46 12.46 SO, 0.00 0.01 0.01 VOC 0.13 0.96 1 0.96 The emissions of PM-.;,CO,NOx, SO,),and VOC are from combustion of LPG in the rotary dryer, and are calculated using the NCDENR Liquefied Petroleum Gas(LPG) Combustion Calculator. The 2013 actual emissions are taken from the 2013 AQEI Report. PM and PM,o Emission factors for this facility are as follows: EF is Process Source PM EF PM10 EF Before Source of EF Description Source ID Rate lb/ton lb/ton or After Tons/hr Control? ES-9S 1 AP-42 Table 11.12-2 Cement/Flyash ES-9S2 6.412 0.00099 0.00034 After Cement Unloading to Silos ES-1 IS Elevated Storage Silo ES-12S Sand ES-13S 17.841 0.0021 0.00099 Before AP-42 Table 11.12-2 Aggregate Silo Aggregate Transfer Gravel Aggregate ES-13S 10.747 0.0069 0.0033 Before AP-42 Table 11.12-2 Silo Sand Transfer NCDENR Concrete Packaging ES-4 35 0.028 0.0105 After Batching Calculator Truck Mix Sand Silo ES-6 17.841 0.0021 0.00099 Before AP-42 Table 11.12-2 Sand Transfer AP-42 Table 11.19-1 Dryer ES-1 28.588 0.010 0.005 After Sand Dryer with Fabric Filter-Includes PM from combustion The Quikrete Companies—Peachland Plant Permit R10 Review Page 5 of 6 Process rates in the table above are based on a maximum production rate of cement mix of 35 tons per hour, and the following proportions in the mix: Cement 366.4 lbs Sand 1019.5 lbs Gravel 614.1 lbs Total Mix 2000.0 lbs For the sand dryer,the PM10 EF is assumed to be 50%of the PM EF(no listing in AP-42). Bagfi Iter control efficiencies are assumed to be 99.9%. 8. Facility Wide Air toxics: There are no toxic pollutant emissions increases expected due to this permit action. Therefore,no toxics demonstration is required. The facility has never modeled toxic emissions. There is neither a 02D .1100 nor a 02Q .0711 toxics condition in the permit. 9. Facility Compliance Status: 10/30/20 NOD issued for altering air emission sources without first obtaining a permit. 09/04/20 The latest facility compliance inspection was conducted by Mike Turner. The facility was found to be in apparent compliance. 09/16/09 The facility was inspected 11 times by Cindy Grimes,Robert Hayden, Daniel Thoma, Through and Mike Thomas. The facility was found to be in apparent compliance during each of 06/20/19 these inspections. The Quikrete Companies—Peachland Plant Permit R10 Review Page 6 of 6 10. Stipulation Review: The following regulations are applicable to this facility: Regulation Affected Sources Emission Limit or Requirement ent 15A NCAC 02D .0515 Facility-wide Control particulate emission 15A NCAC 02D .0516 Facility-wide SO,<2.3 lb/mmBtu heat input 15A NCAC 02D .0521 All sources 20%opacity 15A NCAC 02D .0535 Facility-wide Notification requirement 15A NCAC 02D .0540 Facility-wide Fugitive Dust Fabric Filter Requirements Bagfilters CD-2,CD-8, Annual Internal Inspection 15A NCAC 02D .0611 CD-12,CD-13,CD-14, Periodic I&M per manufacturer's CD-15,CD-16,CD-17 recommendations Recordkeeping 15A NCAC 02D .1806 Facility-wide Odors PM 10< 100 tons per consecutive 12-month period 15A NCAC 02Q .0315 Facility-wide I&M and Recordkeeping for fabric filters per the 2D .0611 permit condition 11. Conclusions,Comments,and Recommendations: I recommend that air permit 069907R10 be issued for The Quikrete Companies—Peachland Plant with the following modification to IBEAM Permit Writer: • Adjusted column widths, bolded and shaded to improve appearance. • Modified the 02Q .0315 permit condition Recordkeeping requirements to remove the statement"...The Permittee shall record monthly and total annually the following..." Review Engineer: Date: O f D w r Permit Coordinator: `a Date: AQ Supervisor: Date: zo \GWR cc: FRO Files Comprehensive Application Report for 0400037.2013 12/16/2020 The Quikrete Companies- Peachland Plant- Peachland(0400037) Anson County General Information: Permit/Latest Revision: 06907/RIO Application Dates Permit code: State Received Completeness Due Clock Start Calculated Issue Due Application type: Modification 12/01/2020 01/15/2021 12/07/2020 03/07/2021 Engineer/Rev. location: Gregory Reeves/FRO Fee Information Regional Contact: Jeffrey D.Cole Initial amount: Date received: Amount Due: Add. Amt Rcv'd: Date Rcv'd: Facility location: Fayetteville Regional Office 400.00 Current Class/Status: Synthetic Minor Fund type: Deposit Slip#: Location rec'd: Location deposited: Clock is ON Application is COMPLETE 2331 Status is : Issued Contact Information Type Name Address City State ZIP Telephone Technical/Permit Braden Keiger 500 Marathon Parkway Lawrenceville,GA 30046 (678)234-3344 Authorized Leroy Bean, Plant Manager P O Box 99 Peachland,NC 28133 (704)272-7677 Acceptance Criteria Completeness Criteria Received? Acceptance Criteria Description Received? Complete Item Description Yes Application fee or ePay Yes Appropriate number of apps submitted N/A Zoning Addressed Yes Authorized signature N/A PE Seal N/A CN -Const.Notice Complete N/A CN - Fac.Name& Location N/A CN -Permittee Name&Address N/A CN- Per.No. of All DAQ Permits N/A CN- Prop. Equip. List& Descrip. N/A CN-Prop. CD(s)List& Descrip. N/A CN-Est. Emissions Asso.w/Mod. N/A CN-Sch. for Alter.& Expansion 1 Comprehensive Application Report for 0400037.20B 12/16/2020 The Quikrete Companies- Peachland Plant- Peachland(0400037) Anson County N/A CN - Will Not Operate Statement N/A CN - Financial Risk Statement N/A CN - Proof of Public Notice N/A CN -Certification of Completeness N/A CN -Fee received N/A Application contains toxic modification(s) Application Events Event Start Due Complete Comments Staff Completeness additional information request 12/01/2020 12/31/2020 12/07/2020 Needed updated B and C forms gwreeves Acknowledgment letter due 12/07/2020 12/17/2020 12/07/2020 jdcole2 Permit issued 12/14/2020 03/07/2021 12/14/2020 gwreeves 2 Comprehensive Application Report for 0400037.20B 12/16/2020 The Quikrete Companies- Peachland Plant- Peachland(0400037) Anson County Outcome Jbtakmation Class before: Synthetic Minor Class after: Synthetic Minor Permit/Revision: 06907/R10 2Q .0711: No 2D .1100: No Revision Issue Date: 12/14/2020 NSPS: No NESHAPS/MACT: No PSD/NSR: No Accumulated process days(includes public notice periods): 7 PSD/NSR Avoid: No Prohibitory Small: No Public notice/hearing/add info after 80 daysNo PSD/NSR Status After: Minor General permit: No Manager's discretion: Appealed? No Multi-site permit: No Multi. permits at facility: No Current Permit Information: Quarry permit: No Recycled Oil Condition: No Issue Effective Expiration Revision# SB3 BACT: No HAP Major(10/25 tpy): Minor 12/14/2020 12/14/2020 10/31/2022 R10 2Q .0705 Last MACT/Toxics: NO NESHAPS/GACT: NO New Source RACT/LAER: NO Existing Source RACT: NO RACT/LAER Added Fee: NO RACT Avoidance: NO 2Q .0702(a)(18)-Toxics/Combustion Source(s)After 07/10/10: NO 1l20)/112(d): NO Regulations Pertaining to this Permit Reference Rule Regulation Description 2D .1806 Control And Prohibition of Odorous Emissions 2D .0611 Monitoring Emissions from Other Sources 2D .0202 Registration of Air Pollution Sources 2Q .0315 Synthetic Minor Facilities 2D .0515 Particulates from Miscellaneous Industrial Processes 2D .0516 Sulfur Dioxide Emissions from Combustion Sources 2D .0521 Control of Visible Emissions 2D .0535 Excess Emissions Reporting and Malfunctions 3 Comprehensive Application Report for 0400037.20B 12/16/2020 The Quikrete Companies- Peachland Plant- Peachland(0400037) Anson County Audit Information Pertaining to this Application Column Name Date Chance Old Value New Value Editor 4