AQ_F_1700009_20220607_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY Southside Materials,LLC-Shelton Quarry
NC Facility ID 1700009
Inspection Report County/FIPS: Caswell/033
Date: 06/10/2022
Facility Data Permit Data
Southside Materials,LLC-Shelton Quarry Permit 03370/R17
1524 Rock Quarry Road Issued 8/8/2014
Pelham,NC 27311 Expires 7/31/2022
Lat: 36d 32.1480m Long: 79d 27.6000m Class/Status Small
SIC: 1423/Crushed And Broken Granite Permit Status Active
NAILS: 212313/Crushed and Broken Granite Mining and Quarrying Current Permit Application(s)Renewal
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Jim Raines M.J.O'Brien,Jr. A.Scott Ross NSPS: Subpart 000
Mine Manager President Director of Engineering
[phone] [phone] &IT
[phone]
Compliance Data
Comments: See Permit Discussion.
Inspection Date 06/07/2022
Inspector's Name Blair Palmer
Inspector's Signature: DMM Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: 06/13/2022 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2013 4.20 --- --- --- --- 1.80 ---
2008 5.34 --- --- --- --- 1.93 ---
Highest HAP Emitted in ounds
Five Year Violation History:
Date Letter Tyne Rule Violated Violation Resolution Date
06/04/2019 NOV 2D .0501 Compliance with Emission Control Standards 09/30/2019
06/04/2019 NOV Part 60-NSPS Subpart 000 Nonmetallic Mineral 08/08/2019
Processing Plants
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
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PERMITTED EMISSION SOURCES:
._......_._._._._...................... ......_.. .._..........................._.._..............._..__ ........................ W ._.. .._......�......._.......w�_...__... ...��.__.... ._.._..._..._.._.__...W..W...:_...._..�.�..__..___..........
......._......
.:......_................
_........
..
Emission Emission Source Control Control System
Source ID Description System ID Description
Non-Metallic Mineral Processing Plant,utilizing water suppression with no other control devices,including:
....... ..__-_._-..........
....�.W............
...... .. ............ ..._. ........................ ........
ES-Screen
Screening Operations i_.._._._._. . . _._.N/A._.__. ._. .. (..... . _N/A.. .
. ............ .. .........._......... ...... _ _._ ...__ ._._._..
ES-Crush Crushin O eration N/A N/A
1...- g_p
—ES-Convey Conveying Operations N/A N/A
_ ............
INSIGNIFICANT/EXEMPT ACTIVITIES:
Source of Title V'.
Source Exemption Regulation F
ource of TAPS? Pollutants?
IES-Silo-1 silo with ba�lter 2Q .0102 (c)(2)(E)(i) � Yes Yes- 65 ton cement
IIES-Weld-1 -portable diesel-fired welder(32.6 hp) 2Q .0102 (c)(1)(L)(ii) Yes � Yes
DISCUSSION:
Southside Materials, LLC - Shelton Quarry crushes various stone sizes,which are used for multiple purposes, such as road
construction. On June 7,2022, Mr. Blair Palmer, DAQ-WSRO Environmental Specialist II, contacted Mr. Jim Raines,
Plant Manager for Southside Materials, LLC—Shelton Quarry,for the purpose of an unannounced compliance inspection.
The facility was last inspected on November 20,2020, by Mr. Palmer, and the facility appeared to comply at that time.
The facility is open for business Monday-Friday, 8-10 hours/day, and 51 weeks/year at present. It is not recommended for
DAQ personnel to conduct inspections during freezing weather, especially if there are or recently have been ambient air
temperatures afor below 32 degrees Fahrenheit because the plant relies on water for the crushing operations. Latitude and
Longitude coordinates have been previously verified in the IBEAM database. A small change has been made in IBEAM
about Mr.Raines's contact information, and no other contact changes are required.
APPLICABLE REGULATIONS:
The applicable air quality regulations as listed in Condition A.1 of Air Permit No. 03370R17 are: 2D .0202, 2D .0501, 2D
.0510, 2D .0521, .0524(40 CFR 60 Subpart 000), 2D .0535, 2D .0540,2D .1806, and 2Q .0309. This permitted facility
is not required to implement a Section 112(r)risk management plan under the federal regulation 40 CFR 68 because they
do not produce, use,or store any regulated chemicals in quantities above the threshold limits. However,the General Duty
Clause contained in this rule applies to all facilities and requires the safe and responsible handling of hazardous materials
in any quantity.
SAFETY:
Quarry pit blasting can occur on occasions. A safety vest, shoes, and eyewear are required at the plant. Mr.Palmer
searched this quarry(MSHA Mine ID: 3100085)under the Mine Data Retrieval System (MDRS),as part of the Mine
Safety and Health Administration(MSHA),for any on-site accidents within the past four years. None were found. The
data can be accessed here: https://www.msha.gov/mine-data-retrieval-system under MSHA Mine ID No. 3100085.
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PROCESS AND INSPECTION:
The process begins with holes drilled into the quarry walls,usually on a vertical axis. After.holes are drilled,a mixture of
ammonium nitrate and other material is ignited with blasting caps causing an explosion,causing the rock to break into
pieces of various sizes,which fall mainly into the quarry floor and roads leading into and out of the quarry. The loose
stone is picked up by approximately 50-ton front-end loaders and placed into piles known in the industry as "Muck Piles."
The piles are occasionally watered by the facility's water truck to prevent fugitive dust before being transported by 50-70-
ton dump trucks and offloaded into the dump hopper and associated feeder. The rock is then fed into the primary jaw
crusher and then routed to the remaining circuit of various conveyors, screens, and secondary crushers. The crushed
pieces of rock eventually are stockpiled into different diameter stones. Some RIP-RAP is also made at this location. The
following are the examples of stone crushed at this location:
78M(crushed stone)-Used in the asphalt and concrete industry.
57, 67, (crushed stone)-Also used in the concrete and asphalt industry.
No. 4, 5, and 66(crushed stone)-Used or placed around septic tank drainage(nitrification) lines
Aggregate Base Course(ABC)-Crushed stone used for road bases,building pads, residential driveways,
and some parking lots.
Most plant operations were in operation or crushing stone during the DAQ inspection. The exceptions were as follows:
CS-11, CS-12, and B-11. FH-01, C-17,and C-18 are part of the portable plant operations;they were also not in operation.
The plant was operating at approximately 500 tons/hr with a primary jaw-crushing setting of six inches.
The facility's permit-exempt sources include IES-Silo-1, a 65-ton cement silo with a bag filter. However,this silo is no
longer used and has not been in several years. IES-Weld, a portable diesel-fired welder(32.6 hp), is used occasionally.
PERMIT CONDITIONS:
Condition A.2(21) .0202)deals with "Registration of Air Pollution Sources."The permit for this facility expires on July
31, 2022. At least 90 days before the expiration of this permit,the Permittee shall submit a permit renewal and an
emissions inventory for the 2021 calendar year. The facility's permit renewal and emissions inventory were received in
the WSRO on time and are currently being processed by Chengqing Xiao, WSRO Environmental Engineer. Compliance
is indicated at this time.
Condition A.3 contains the 15A NCAC 2D .0501(c)equipment reporting requirement. This condition requires this
facility to maintain an on-site equipment list and plant flow diagram of all equipment covered under this permit.
• The total rated crushing capacity of all primary crushers.
• A description of equipment, including NSPS applicability.
• Width of belt conveyors.
• Dimensions and configurations of screens.
• Rated capacity of each crusher.
• Rated capacity of all equipment not exempt from permit requirements under 2Q .0102.
• A unique ID number.
• Date of equipment manufacture.
• Date any required performance testing was conducted and submitted to NC-DAQ.
The facility has replaced Item No, 2 in December 2021,an NSPS-subject jaw crusher,which is slightly lower in terms of
crushing capacity. This jaw crusher is also discussed under the NSPS section of this report. The facility had an updated
equipment list,but it was not dated,and the manufacturer date is incorrect on the information provided during the
inspection. Also,the flow diagram for the facility was not dated. After discussion with NCDAQ WSRO management,
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the facility will be required to send to the WSRO the updated information mentioned above as soon as possible.
Compliance with this condition and 2Q .0501(c) is likely, but pending information is needed. By telephone,Mr. Palmer
!, communicated this to Mr. Scott Ross,Director of Engineering&IT for Southside Materials.
Condition AA contains the 15A NCAC 2D .0510, "Particulate Control Requirement." This condition requires the
Permittee to not produce materials in such a manner that PM, PMlo,and total suspended particle ambient air quality
standards are exceeded beyond the property boundary. Additionally,the facility must control fugitive dust emissions as
1 required by 15A NCAC 2D .0540(and permit condition A.11)and prevent process-generated emissions from crushers
with wet suppression so that all applicable opacity standards are met. Compliance with this condition can be expected.
Mr. Palmer observed no visible emissions from the facility's haul roads.
Condition A.5 contains the requirements for the primary crusher specifications. The primary jaw crusher is rated at a
maximum of 650 tons per hour with a 10-inch diameter setting. However, as mentioned above,Mr. Palmer was informed
as part of the inspection that the jaw crusher now has a maximum capacity of 645 tons per hour since it was replaced in
December 2021. The current crusher generally operates at a 6-7" setting and it has an average throughput of
approximately 500 tons per hour. The facility must submit a permit application for any changes to the crusher that are not
considered "like-for-like." compliance is expected.
Conditions A.6 and A.7 contain the 2D .0521 visible emissions control requirement. This condition limits sources to 20
percent or 40 percent opacity, depending on the manufacture date. It should be noted that 40 CFR Part 60, Subpart 000
limits many of these sources to more stringent visible emissions standards than the limits listed in 2D .0521 and is
discussed below. Mr. Palmer observed no visible emissions from the subject equipment, indicating likely compliance.
Condition A.8(21) .0524, 40 CFR 60, Subpart 000)pertains to "New Source Performance Standards(NSPS)." The
requirements are as follows:
• In accordance with §60.676, the facility must notify DAQ within 15 days of the startup of a new source.
• Per 40 CFR§60.672, a 15% opacity limit is set for any crushers. A 10% opacity limit is assessed for any
screening operations, conveyor belts,and other sources constructed and modified after August 31, 1983, but
before April 22,2008.
• In accordance with 40 CFR§60.672,a 12% opacity limit is set for any crushers,and a 7%opacity limit is for any
screening operations, conveyor belts,and other sources constructed and modified on or after April 22, 2008.
• In accordance with §60.674(b),the facility must perform monthly inspections of the wet suppression system for
equipment constructed on or after April 22, 2008. It must keep records on-site and available to DAQ personnel
upon request.
• According to §60.672(b),the facility must conduct performance testing on any affected source within 60 days of
achieving maximum production but no later than 180 days after the initial startup. Once the required performance
test is performed,the facility must submit two copies of the report to the Regional Supervisor of DAQ.
• The facility must submit a testing protocol to DAQ at least 45 days before testing,and at least seven days advance
notice must be provided in writing to the Division so an observer from DAQ can be present for the test.
• According to §60.670(d),the regulation allows the facility to be exempt from testing if they replace equipment
that is equal to or less than the production capacity of the equipment being replaced. The part of the regulation is
also known as Like-For-Like-Replacement.
The facility performs monthly periodic inspections to check that water is flowing to discharge nozzles on wet suppression
systems for sources that were constructed on or after April 22, 2008. The plant records each inspection, including the date
and any corrective action taken in a logbook that can be made available to DAQ personnel upon request. The facility
performs inspections on all subject 000 equipment regardless of whether it was constructed before April 22,2008 (even
though they are not required to do so). The facility performs daily inspections on the equipment;the last inspections
occurred on June 6,2022;Mr. Palmer reviewed records since the DAQ inspection conducted on November 20,2020.
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Very few problems were noted back in the previous DAQ inspection. Plant personnel keeps extra water nozzles and
valves in inventory for any issues that may arise for the water suppression system. The facility currently has one piece
(Item No. 2-Jaw Crusher) subject equipment on or after April 22,2008. The conveyor list and process usage were also
reviewed for NSPS compliance. Conveyor C-8,manufactured in 2006, is the latest equipment tested on August 8,2019
(determined to comply)due to discovery during the May 7 and 21, 2019 inspections by WSRO DAQ staff. The facility
did not have C-8 tested previously, but it was tested on August 8,2019. As mentioned earlier,the facility's jaw crusher
has been replaced and qualifies for Like-Like-Replacement. The required notification is forthcoming and will be
submitted to the WSRO soon.
Compliance is indicated.
Condition A.9 contains the 15A NCAC 2D .0535 rule. This regulation includes requirements relating to reporting excess
emissions,malfunctions, and breakdown of process or control equipment that lead to releasing excess emissions that last
longer than four hours. The facility is to notify WSRO-DAQ by 9:00 A.M the following business day. The facility is to
provide the name and location of the facility,the nature and cause of the malfunction or breakdown,the time when the
malfunction or breakdown was first observed,the expected duration,and an estimated emission rate. The facility must
also notify the Director when the corrective action has been accomplished. Mr. Raines indicated that there had not been
any such incidents, indicating that the facility is likely in compliance.
Condition A.10 contains the 15A NCAC 2D .0540 fugitive dust control requirement. Mr. Palmer did not observe any dust
problems during the inspection or evaluation. Mr. Raines commented that a designated water truck is used when
necessary. Water is used from the lower pit area or pumped into a holding pond. Compliance with the condition is
likely.
Condition A.11 contains the 15A NCAC 2D .1806 control of odorous emissions requirement. No objectionable odors
around the facility boundary were noted during the last inspection. There have been no complaints regarding odors at the
facility. Compliance with the condition can be expected.
Condition A.12 pertains to "Permit Reopening" and 2Q .0309, "Termination,Modification, and Revocation of Permits."
Per NCGS 143-215.108(c),upon the Director becoming aware of any credible air emissions data not previously
considered by the DAQ during the application review process,the Director may require the Permittee to submit additional
information including,but not limited to, emissions estimates and air dispersion modeling. Based on this information,the
Director may modify and reissue the permit with additional emission controls or operational restrictions necessary to
demonstrate compliance with applicable regulations. There is currently no apparent reason to have the DAQ Director
modify and reissue the current air permit for this facility. There have been no credible air emissions data or air dispersion
modeling not previously considered during any permit application process.
FACILITY-WIDE EMISSIONS:
As referenced in the latest permit renewal R17(Davis Murphy, Environmental Engineer/Permit Coordinator 08/08/2014)
and based on emissions from the calendar year 2013,the facility-wide potential and actual emissions are listed in the table
below:
Pollutant, Cy 2013 Actu y Emissions a ,. Potential`Emissions(Tgns/Year)
Tons/I'ear
PM 4.2 45.678
PM10 1.8 17.287
PM2.5 0.7 3.7
Arsenic 0 4.643 e-07
Beryllium 0 5.322e-08
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Pollutant CY 2013 Actual Ern sslons Potential Emissions(Tons/Year)
r t�L fr
Tons/Year.
Total Chromium 0 3.175e-06
Lead 0 1.193e-06
Manganese 0 1.28le-05
Nickel 0 4.577e-06
As mentioned earlier,the facility crushed approximately 700,000 tons in CY 2021,and this figure is more than in CYs
2019-2020. The above emissions appear to be reasonable.
MACT/GACT:
The facility does not have an emergency generator at the current time. The facility has no gasoline tanks and thus no
gasoline dispensing equipment.
COMPLIANCE HISTORY(within the last five years):
• A Notice of Violation(NOV)was issued June 4,2019, for failure to comply with the requirements associated
with 15A 2D .0501(c), specifically not maintaining on-site an updated equipment list and plant flow diagram of
all equipment covered under this permit. Also,the facility was found in violation of 40 CFR Part 60, Subpart
000 "Standards of Performance for Nonmetallic Mineral Processing Plants," and 15A NCAC 2D .0524 for
failure to report the actual date of initial startup and conduct performance testing on Conveyor C-8. Testing was
completed on August 8, 2019, and a WSRO-DAQ letter was sent to the facility on September 23, 2019, indicating
compliance.
PERMIT DISCUSSION:
• Condition A.5 contains the requirements for the primary crusher specifications. Mr. Palmer was informed as part
of the June 7, 2022 inspection that the jaw crusher now has a maximum capacity of 645 tons per hour,not 650
tons per hour. The jaw setting remains at 10 inches.
• IES-Silo-1 ----65-ton cement silo with bagfilter is no longer used.
• The IES-Weld-l-portable diesel-fired welder(32.6 hp)should reflect the most current permit exemption
due to 2016 DAQ rule changes.
• Rule 2Q .0309, Termination, Modification, and Revocation of Permits. This permit condition should be removed
from the permit. WSRO previously had the policy to add this permit condition to all permits for rock quarries,
concrete batch plants, asphalt plants, and other facilities with histories of noncompliance. The general permit
condition B.6 references this regulation already, so it does not need to be listed in the permit.
• This facility is no longer subject to the rule 2D .0501, "Compliance with Emission Control Standards." 0605, "General
Recordkeeping and Reporting Requirements" should include a condition known as "QUARRY EQUIPMENT
REPORTING." also, a reporting requirement should be listed in the next revision and under 2D to keep a flexible quarry
permit.
CONCLUSION:
Based on observations and records review,this facility appeared to be operating in compliance with Air Quality standards
and regulations at the time of the June 7,2022 inspection.
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