HomeMy WebLinkAboutAQ_F_1000127_20200925_CMPL_InspRpt r
NORTH CAROLINA DIVISION OF Wilmington Regional Office
AIR QUALITY Chuck's Construction Mine
NC Facility ID 1000127
Inspection Report County/FIPS: Brunswick/019
Date: 09/25/2020
Facility Data Permit Data
Chuck's Construction Mine Permit 10643 /G01
1520 Hickman Rd NW Issued 5/20/2020
Calabash,NC 28467 Expires 12/31/2024
Lat: 33d 55.7316m Long: 78d 37.5900m Classification Title V
SIC: 4953/Refuse Systems Permit Status Active
NAILS: 562213 /Solid Waste Combustors and Incinerators Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SEP
William Bellamy William Bellamy William Bellamy NSPS: Subpart EEEE
Owner/Operator Owner/Operator Owner/Operator
(843)458-0258 (843)458-0258 (843)458-0258
Compliance Data
Comments: Inspect facility as scheduled.
Inspection Date 08/27/2020
Inspector's Name Scott Sanders
Inspector's Signature: Scott Sanders C Operating Status Operating
Compliance Code Compliance- inspection
Action Code FCE
Date of Signature: 9/25/20 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
No emissions inventory on record. The emissions inventory is due June 30' of every year.
* Highest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Tvae Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
Directions to the facility are as follows: From WiRO,turn right onto Cardinal Drive. Turn left onto
Market St. Turn right onto US-74 W MLK Pkwy. Use the right lane to merge onto NC-133 S/US-
74 W/Isabel Holmes Bridge via the ramp to Whiteville. Use the left 2 lanes to turn left onto US-421
S/US-74 W. Keep right at the fork, follow signs for US-17 S/US-74 WIUS-76 W/NC-133
Chuck's Construction Mine
September 25,2020
SBrunswick Co. Beaches and merge onto NC-133 SIUS-17 S/US-74 W/US-76 W. Continue to
follow US-17 S/US-74 W/US-76 W for 2.6 miles. Use the right 2 lanes to take the US-17 exit
toward Shallotte/Myrtle Beach. Continue onto US-17 S/Ocean Hwy E for approximately 41 miles.
Turn right onto Hickman Rd NW just past Brunswick Plantation. Continue for 3.4 miles and the
facility will be on the right and down an access road that goes to the air curtain burner location.
1. Contact was made onsite with William (Chuck) Bellamy, Owner/Operator, to conduct a Full
Compliance Evaluation(FCE).
2. Applicable regulations for Chuck's Construction Mine are as follows:
2D .1904 "Air Curtain Incinerators"
2D .0524 "New Source Performance Standards (NSPS)40 CFR Part 60 Subpart
EEEE — Standards of Performance for Other Solid Waste Incineration Units"
(only 40 CFR 60.2970 through 60.2974)
2D. 1806 "Control and Prohibition of Odorous Emissions"
2Q. 0510 "Permitting of Facilities at Multiple Temporary Sites"
3. The following table contains a summary of all permitted emission sources and associated air
pollution control devices and appurtenances contained in Permit No. 10643GOI:
Emission
Source Control Device
ID No. Emission Source Description ID No. Control Device Description
ACI McPherson M30G N/A N/A
NSPS EEEE Trench Burner
8 tons per hour firing capacity)
The following table provides a summary of limits and standards for the emission source(s)
described above:
Regulated
Pollutant Limits/Standards Applicable Regulation
Visible Work Practices 15A NCAC 02D .1904
Emissions
Visible 10 percent opacity(6-minute average),except 15A NCAC 02D .0524
Emissions 35 percent opacity(6-minute average)during the NSPS 40 CFR Part 60 Subpart
startup period that is within the first 30 minutes of EEEE
operation.
Odorous State-enforceable Only 15A NCAC 02D .1806
Emissions
Visible The Permittee shall notify the Division in writing at 15A NCAC 02Q .0510
Emissions least 10 days in advance of each change of location.
Page 2 of 5
Chuck's Construction Mine
September 25,2020
4. An air curtain incinerator (ACI) means a stationary or portable incinerator that operates by
forcefully projecting a curtain of air across an open,integrated combustion chamber(firebox)or
open pit or trench(trench burner) in which combustion occurs.
This facility was originally permitted for an air curtain incinerator [Trench Burner T-300
made by Air Burners, Inc.] (ID No. ACI). The facility requested to replace that air curtain
incinerator (ACI) with a very similar trench burner made by McPherson Systems, Inc.
(M30G).
This new (commenced construction after December 9, 2004) portable trench burner model
M30G, is equipped with a 30 foot manifold and is able to burn 8 tons per hour of only wood
waste consisting of trees, logs, large brush, stumps relatively free of soil, and clean lumber.
The recent permit modification(dated May 20, 2020) was processed as a minor modification
under 15A NCAC 02Q .0515 to allow this portable air curtain incinerator to operate the same
as the original air curtain incinerator with only a change in the manufacturer noted above.
Also, this minor modification will allow the portable air curtain incinerator to move to other
permitted sites with proper notification pursuant to 15A NCAC 02Q .0510.
The appropriate fee for this minor modification[$98(10%of the applicable fee)]was received
on April 8, 2020.
5. This site was discovered on July 8, 2019 in response to a complaint received from the NC
Forest Service on July 1, 2019. The complaint from Bill Walker, County Ranger, stated one
of their airplanes spotted a fire at this location. Their investigation revealed that a land
clearing business was bringing in large size vegetative debris (palm trees, etc.) into this
location from offsite and then open burning the debris. They observed two large piles of
vegetative debris. One of the piles was observed burning. Nobody was onsite attending the
fire at the time. On July 8, 2019, I observed one large pile of land clearing debris (40 X 20 X
8) burning and took pictures. I contacted the property owner, Chuck Bellamy, after seeing
his business information on a sign out by the road. He indicated that their company(Chuck's
Construction Co., Inc.) does land clearing contracting and that the debris present onsite was
not routine maintenance or property cleanup. I explained the open burning rules to Mr.
Bellamy including the transport part of the rule (4 times per year, etc.) and also about air
curtain burners. He indicated then that he was very interested in purchasing an air curtain
burner for use at this location and getting an air permit for it. He indicated a tub grinder was
way too costly and it would likely be difficult to get rid of the wood chips. I evaluated this
site and determined it would be very good for an air curtain burner operation. There are no
occupied dwellings anywhere close by and the burn site is way back off the main road.
Chuck's home and office location are just down the road from this burn site. He resides at
2205 Worthams Cut Off Road, Little River, SC 29566. The office location is 1803 Highway
57 North, Little River, SC 29566 and the mailing address is P.O. Box 1380, Little River, SC
29566. A certified General Information letter was sent to Chuck's Construction Company,
Inc. on July 17,2019 based on information gathered during my July 8, 2019 investigation. A
copy of this letter was previously attached for reference.
Page 3 of 5
Chuck's Construction Mine
September 25,2020
6. Dean Carroll and I met with Mr. Chuck Bellamy and his son, Charlie, on August 8, 2019 to
assist them with filling out an air permit application for an air curtain burner at this site. After
some time went by, a zoning consistency determination was finally approved by Ms. Helen
Evans Bunch, Zoning Administrator of the Brunswick County Planning Department, on
November 26, 2019. The original air permit was issued on January 15, 2020.
7. On January 24, 2020, I contacted Mr. Chuck Bellamy. He informed me that he had recently
been to Florida to look at and purchase the new Air Burners T-300 Trench Burner listed in
the previous emissions source description of the permit. After viewing the small, foreign 53
horsepower engine installed on the Air Burners T-300 unit, he decided against the purchase.
He indicated that he would likely have to run that unit wide open, that it probably would not
produce enough airflow necessary for good combustion, and the maintenance on it would be
more difficult. He indicated that he decided to purchase a new McPherson Systems, Inc. unit
located in Georgia. This unit is set up the same as the Air Burners T-300,but has more power
and comes equipped with a large 74 horsepower John Deere engine. Mr. Bellamy sent me
the specs on the McPherson unit (M30G Air Curtain Destructor). These were previously
attached for reference.
8. Mr. Bellamy purchased the new McPherson M30G Trench Burner (8 tons per hour firing
capacity) on February 22, 2020 at a cost of $52,000. Mr. Bellamy submitted updated air
permit application forms for the McPherson unit(M30G) and a small fee of$98 (10% of the
Title V permit modification fee). DAQ WiRO received the $98 from Chuck's Construction
on April 8, 2020. On May 12, 2020 Jeff Twisdale, RCO Permit Writer, sent the draft permit
and review to DAQ WiRO for comments. The draft permit was sent to Chuck's Construction
on May 12, 2020 and no comments were received. Issuance of General Title V Permit
10643G01 for this air curtain incinerator to the facility occurred on May 20, 2020.
9. Contact was made onsite at the facility location with Mr. Chuck Bellamy on August 27,2020.
No burning was occurring during the inspection. Mr. Bellamy informed DAQ that startup of
this unit occurred last month (early July). He indicated that they have burned with the ACI
eight to ten times already and are burning one day per week. He indicated the last burn was
two days ago. Mr. Bellamy indicated that they would soon be performing the required initial
Method 9 performance test and would let me know when this will occur so I could be present.
Mr. Bellamy is aware of the recordkeeping requirements stating they shall keep a daily log of
specific materials burned and the amounts of material burned.
10. Mr. Charlie Bellamy attended the ETA smoke school field session training on June 11, 2020
in Wilmington, NC and passed on the first ran. This training was originally scheduled for
May 6-7,2020 but was postponed due to the Covid-19 pandemic. Also due to Covid-19,ETA
is currently only offering the classroom part of smoke school training as a live lecture webinar
every Tuesday at 9:00 am. Mr. Bellamy has also viewed the webinar.
11. Mr. Bellamy was informed of the Testing requirements pursuant to 15A NCAC 02Q 0508 (f),
40 CFR 60.2972 stating within 60 days after the air curtain incinerator reaches the charge rate
at which it will operate, but no later than 180 days after its initial startup, an initial Method 9
performance test for opacity as specified in 40 CFR 60.8 shall be conducted to determine
Page 4 of 5
Chuck's Construction Mine
September 25,2020
compliance with the opacity limitations. Per recent guidance from Gary Saunders(RCO),the
rules require three one-hour runs to produce a total of 30 6-minute averages (15-second
readings) for the initial and subsequent performance testing. Mr. Bellamy was informed to
notify DAQ at least 15 days before beginning the test so that DAQ may observe the test.
This test was performed on September 24, 2020. I was present for most of the test and it
appeared to go well. After a cold startup of the unit,the test began at 10:30 am. The majority
of the readings were in the 5-10% opacity range throughout the test and results indicate that
all the 6-minute averages were less than 10% opacity. It appears the air curtain incinerator
successfully passed the Method 9 test. Mr. Bellamy's tests sheets (and mine) and a copy of
his smoke school certificate are attached for reference and will be sent to RCO soon.
12. This facility is operating under a General Title V Air Quality Permit for Air Curtain
Incinerators. Permitted air curtain incinerators now qualify for a fee of only 10% of the
normal Title V fee for permit applications and the annual permit fee. Jeff Twisdale, DAQ
Environmental Engineer in the Raleigh Central Office, is the permit writer for air curtain
incinerators which includes writing the permits for new and existing ACIs and any future
permit modifications as well.
13.NC DEQ—Division of Waste Management—Solid Waste Section issued a DS number(DS 10-
077) on September 5, 2019 for the facility to be a Temporary Disaster Debris Staging Site.
The facility also has a Yard Waste Notification permit (YWN-10-011) from DWM. YWN
permits are required to be renewed online every year by June 1'. These permits were
previously attached for reference.
14. Chuck's Construction Mine appears to be in compliance with all applicable Air Quality
regulations.
Page 5 of 5
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This certifies that
Charles Bellamy
successfully completed a course in the methods of measurement of visible emissions from
stationary sources as specified by Federal Reference Methods 9, 22, and 203 A, 13, and C. This
training course was conducted by Eastern Technical Associates, Inc. of Raleigh. N,C,
Tuosft,Jww 16, 2020
Course Location Student ID Number Dift
Jody Monk
General Managiar
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DISTANCE FROM OBSERVER DIRECTION FROM OBSERVER ,2 0 a le;
Stet End SIM End
DESCRIBE EMISSIONS D (D (O (D
San End la p ( O
EMISSION COLOR F WATER DROPLET PLUME
's D
Son End AIWMd O DevChed O
POINT IN THE PLUME AT WHICH OPACITY WAS DETERMINED to d D
SEMI End 17 M V
Z) l O
DESCRIBE PLUME BACKGROUND C/ -
San Ed tI 0 Co (a ��
BACKGROUND COLOR SKY CONDITIONS 'I D O D
Sae End Sign End 20 D D /D
WIND SPEED WIND DIRECTION
Son Etl Sun End 21 'o �D [
AMBIENT TEMP I WET BULB TEMP RN. pow 22 (p O rO
San End
23
B+de�`i SOURCE LAYOUT SKETCH Omit NNwm Anw ;29 /
Plum. 17 D
Sun $ O D (a
Wim s
(p D / O
X Emission Paint a (p p (O
30 (D 1 O /a
oB�R�Y!
Olrerver's w�,
Igo• O SIGNATURE _ TT
__ ORGAN TION
—_— Sun Laution Line ---- �DAd--
ADDITIONAL INFORMATION CERTIFI Y DATE
CONTINUED ON VEO FORM NUMBER