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HomeMy WebLinkAboutAQ_F_0400045_20210616_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Hildreth Ready Mix,LLC NC Facility ID 0400045 Inspection Report County/FIPS:Anson/007 Date: 06/24/2021 Facility Data Permit Data Hildreth Ready Mix,LLC Permit 08715/G04 878 City Pond Road-SR 1142 Issued 4/17/2018 Wadesboro,NC 28170 Expires 3/31/2026 Lat: 34d 55.4970m Long: 80d 5.9570m Class/Status Small SIC: 3273/Ready-Mixed Concrete Permit Status Active NAICS: 32732/Ready-Mix Concrete Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Karl Hildreth Karl Hildreth Karl Hildreth Owner Owner Owner (704)694-2034 (704)694-2034 (704)694-2034 Compliance Data Comments: Inspection Date 06/16/2021 Inspector's Name Mike Turner Inspector's Signature: Operating Status Operating Compliance Status Violation-procedures Action Code FCE Date of Signature: Inspection Result Violation Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2417 1.25 --- --- --- --- 0.3800 0.1130 2012 0.7200 --- --- --- --- 0.2200 0.0610 *Highest HAP Emitted(in pounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 03/23/2018 NOV Permit Late Report(excluding ACC) 03/25/2018 03/21/2017 NOV Permit Late Report(excluding ACC) 03/13/2017 Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested I. DIRECTIONS From FRO,head south on Green St toward Maiden Ln for 0.1 miles.At the traffic circle,take the 2nd exit onto Gillespie St for 0.2 miles.Turn right onto W Russell St for 0.5 miles.Turn left onto Robeson St for 2.4 miles.Use the left 2 lanes to turn left onto Raeford Rd for 9.7 miles,then continue onto US-401 S for 20.4 miles.Turn right onto NC-144 W/Old Wire Rd for 6.2 miles.At the traffic circle,take the 2nd exit onto NC-144 for 5.4 miles,then a slight right onto NC-1319 for 0.7 miles. Slight right onto US-74 W and continue for 6.7 miles,then continue onto I-74 W/US-74 W(signs for Rockingham)for 27.4 miles. Turn left onto E Wade St for 0.7 miles. Turn right onto Brent St for 30 ft.Turn left onto E Wade St for 0.2 miles. Turn left at the 2nd cross street onto S Greene St for 0.1 miles. S Greene St turns slightly right and becomes NC-109 S/Camden Rd,continue to follow NC-109 S for 3.1 miles.Turn left onto City Pond Rd.Destination will be on the left in 0.8 miles.If no one is at the plant,take Hildreth Road,which is just past plant,up to the office on the right. II. SAFETY Standard FRO safety gear is required. The inspector should be mindful of vehicular and heavy equipment traffic. III. FACILITY/PROCESS DESCRIPTION Hildreth Ready Mix,LLC is a small truck mix, concrete batch plant. Cement is stored in silos and mixed with aggregate and sand(both stockpiled on site), all of which is mixed with water inside a cement truck. The loadout and silos are controlled by a central dust collector. A second bagfilter,which was previously used as a dedicated control for one of the silos is still in place,but it is no longer operating. IV. PERMITTED EMISSION SOURCES One Concrete batch plant with fabric filter air pollution control system(s)installed on all sources; 1. One(1)cement mixing weigh hopper and loading operation; and, 2. Silos for cement and flyash storage. INSIGNIFICANT/EXEMPT ACTIVITIES: I-1 2Q.0102(h)(5) No Yes Sand and Aggregate Handling Facility was not operating during the inspection. V. INSPECTION SUMMARY On 16 June 2021,I,Mike Turner,with the Fayetteville Regional Office of DAQ,conducted a compliance inspection of the Hildreth Ready Mix,LLC facility,where I met with office manager,Chanel Little. We discussed the following: a) Ms. Little verified the FACFINDER and stated no changes are needed. b) Ms.Little was not able to show me a copy of the permit. c) I viewed the maintenance logbook,which lacked key documentation requirements.See compliance statement under stipulation G,"Fabric Filter Requirement". d) Production: Operating hours Monday through Friday, 8am-3pm. Employees 1 Production(cu yd) 2020: 1,661 2019: 1,106 2018: 6,746 2017: 6,294.5 2016: 4,147 2015: 7,972.5 2014: 65000 2013: 2,000 2012: 3,397 VI. PERMIT CONDITIONS&LIMITATIONS A. 15A NCAC 2D.0202—PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT —The permittee shall submit an application for renewal of the facility's permit no later than 90 days prior to expiration,and shall include documentation of air pollutants emitted for the 2017 calendar year. APPEARED IN COMPLIANCE— The facility submitted their previous emissions inventory and permit renewal before the submittal deadline. The next deadline for submittal of emissions inventory and permit renewal is December 2025 for the 2024 calendar year. B. 15A NCAC 2D .0515—PARTICULATE CONTROL REQUIREMENT—Particulate matter emissions from the emissions sources shall not exceed allowable emission rates, as calculated by the following equations: E=4.10 * (P)0-" for P<3 0 tons/hr, or E=55 * (P)0-11-40 for P>30 tons/hr APPEARED IN COMPLIANCE— Compliance was determined during the most recent permit review based on operating the source as described in the permit conditions. No changes have been made to operations since that determination. C. 15A NCAC 2D .0521-15A NCAC 2D .0521—VISIBLE EMISSIONS CONTROL REQUIREMENTS—Visible emissions from each emission source manufactured after July 1, 1971, shall not exceed 20%opacity when averaged over a six-minute period. APPEARED IN COMPLIANCE— The facility was not operating at the time of this inspection. D. 15A NCAC 2D .0535—NOTIFICATION REQUIREMENT—The facility must notify DAQ in the event of excess emissions lasting longer than 4 hours resulting from malfunctions,breakdowns,or abnormal conditions. APPEARED IN COMPLIANCE— Ms.Little indicated no excess emission events have occurred since the last inspection and therefore no notifications have been required. E 15A NCAC 2D .0540—FUGITIVE DUST CONTROL REQUIREMENT—The Permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. APPEARED IN COMPLIANCE— No fugitive dust concerns at the property boundaries were noted during the inspection.Ms.Little stated they have not received any dust complaints,nor has FRO DAQ received any complaints about this facility. F. 15A NCAC 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—As required by 15A NCAC 2D .1806 "Control and Prohibition of Odorous Emissions"the Permittee shall not operate the facility without implementing management practices or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary. APPEARED TO BE IN COMPLIANCE—I did not detect any objectionable odors upon entering or leaving the facility,nor while I was inside the facility during my inspection. Ms. Little stated this facility has not received any odor complaints and FRO has not received any odor complaints regarding this facility. G. 15A NCAC 2D .0611—FABRIC FILTER REQUIREMENT—Particulate matter emissions from the permitted equipment shall be controlled by fabric filters.Requires periodic inspection and maintenance per manufacturer's recommendations,and an annual internal inspection. All I&M activities,and any variances from requirements,must be documented in a logbook. VIOLATION NOTED—When asked for the I&M logbooks,Ms.Little showed me a page in a loose-leaf notebook that showed the baghouse was checked on 01-12-21 and 05-04-21,and the baghouse was opened and the filters cleaned on 03-16-21.None of these entries has a signature to say who performed a particular activity.I informed Ms.Little the I&M records for this facility do not meet the requirements as outlined in this facility's permit,and reminded her this facility received an NOD last year for the same violation,failure to keep adequate records.I told Ms. Little an acceptable I&M logbook entry will have the date of each I&M activity performed,what activity was performed, any corrections of variances, and the signature or initials of the person who performed each activity,and that this logbook needs to be kept on-site. H. 15A NCAC 2D .1104—TOXIC AIR POLLUTANT CONTROL REQUIREMENTS—The facility shall not emit arsenic in such quantities that may cause an exceedance of the acceptable ambient level(AAL). The concrete production limit for a truck mix facility is based on distance to property boundary(150,000 cubic yards at 196.8 feet),which shall be marked. Monthly record keeping, and notification of changes are also required. APPEARED IN COMPLIANCE— The nearest property boundary is—75' from the emission source. The nearest property boundary limits the facility to 340,500 cubic yards of production annually,and the 1,661 cubic yards of concrete this facility produced in 2020 is well under that limit. I. 15A NCAC 2Q .0310—GENERAL PERMIT CRITERIA,—The facility must meet the following criteria to qualify for a general permit: 1)No emissions sources operated other than those listed;2) facility not subject to regulations other than those covered by the general permit; 3)facility is located in one of the listed counties; 4)maximum hourly throughput does not exceed 13 8 cubic yards per hour; and 5)the facility does not exceed the maximum annual production rate based on distance to the property line(340,500 cubic yards at 75 feet). APPEARED IN COMPLIANCE— The facility appeared to qualify for a general permit. No other emission sources other than those listed were noted,and the facility does not appear to be subject to any regulations, State or Federal,other than those listed in the general permit. The facility is located in Anson County,which is listed in the permit and covered by generalized modeling. The annual throughput, 1,106 cubic yards in 2020, is less than the maximum annual production rate of 340,500 cubics. J. 15A NCAC 2Q.0711—TOXIC AIR POLLUTANT EMISSION LIMITATIONS—For each of the toxic air pollutants(TAPs) listed below, facility-wide actual emissions may not exceed the Toxic Permit Emission Rates(TPERs)listed in 15A NCAC2Q .0711(a): Beryllium 0.28 Cadmium Chromium* 0.013 'Manganese and compounds 0.63 Nickel metal - T m 0.13 Emissions of toxic air pollutants shall not exceed the listed limitations without first obtaining a permit and demonstrating compliance with 2D .1100. APPEARED IN COMPLIANCE— Compliance was determined during the most recent permit review based on operating the source as described in the permit conditions. No changes have been made to operations since that determination. VI. NON-COMPLIANCE HISTORY SINCE 2010 09/28/20 NOD issued for Recordkeeping Requirements. 03/25/18 NOV issued for late annual reporting. 03/21/17 NOV issued for late reporting. 03/28/16 NOD issued for late reporting. 05/28/10 NOV issued for late reporting. VII. 112r APPLICABILITY The facility does not store any of the listed chemicals above the threshold quantities, and is not required to maintain a written Risk Management Plan(RMP). VIII. CONCLUSION AND RECOMMENDATIONS At the time of inspection 16 June 2021,Hildreth Ready Mix,LLC, appeared to be operating IN VIOLATION permit stipulations 15A NCAC 2D .0611 —Fabric Filter Requirements,and 15A NCAC 02Q .0110—Permit Retention Requirement, of their current air permit. I recommend issuing a Notice of Violation letter for failure to maintain adequate logbooks of their inspection and maintenance activities and for failure to keep a copy of their permit on-site. PINK SHEET ADDITIONS: None. /wmt