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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 r C 'W'r OBSERVATION DATE START TWE END TIRE STREET ADOKEss s� t yl ne SIC9-1'/-110 I p: I SZC ep� B is w a ca"VENTS �!+'NFn Awl. 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(�f s PATE _ --- Sun L00/Ian Lro-----_ ON(3AN as ADOITIONAL INFORMATKIN CERTljt Br/ {GG✓/ ���('RI' �.n b CONTINUEO ON VEO FORM NUMBER L I � V I %-J I PJ I 16o "1 119%7%.71%At 1 1%7 V CAI %A CA Ll %wP I I AM 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 ---------- --------------- CDWJAW NAME OBSERVATION DATE START TIME V END TIME L• a. a A STREET ADDRESS Sec Q 0 15 70 45 COMMENTS J K- MIN ' 10 e (e r srATE s s r s CL1•' L G a2 6 yf 9 l e S PHONE IKEY CONTACT) SOURCE IO NUMBER 1 PROCESS EQUIPMENT OPERATING MODE - 5 5— r CONTROL EOUIPMENT OPERATING E A 7 s r a r DESCRIBE EMISSION POINT B Ge f �� •/!ii'(✓tr LAG A.�.J1L 9 to 0 S O HEIGHT ABOVE GROUND LEVEL HEIGHT RELATIVE TO OBSERVER /0 ' Start XAA— End DISTANCE FROM OBSERVER DIRECTION FROM OBSERVER 12 S r s O Stet-$'—Q f End XA]fil— I Start ) End 7 D S O DESCRIBE EMISSIONS / sun : A,4— End „ EMISS COLOR IF WATER DROPLET PLUME /S San G rj'— End AUA~O Detwh9d 0 PANT IN THE PLUME AT WHICH OPACITY WAS DETERMWED is O e • San D End Ater 17 D a • DE PLUME BACKGROUND tg /r O San �Ac-�1/!A.S End AI••�-- BACKGROUND COLOR SKY CONDITIONS to Sane End .Cef1. 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Olrerver's w�, Igo• O SIGNATURE _ TT __ ORGAN TION —_— Sun Laution Line ---- �DAd-- ADDITIONAL INFORMATION CERTIFI Y DATE CONTINUED ON VEO FORM NUMBER