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