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HomeMy WebLinkAboutAQ_F_0400005_20210707_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Adams an Old Castle Company-Lilesville NC Facility ID 0400005 Inspection Report County/FIPS:Anson/007 Date: 07/15/2021 Facility Data Permit Data , Adams an Old Castle Company-Lilesville Permit 01759/R22 351 Hailey's Ferry Road Issued 3/8/2017 Lilesville,NC 28091 Expires 2/28/2025 Lat: 34d 57.5360m Long: 79d 57.4490m Class/Status Synthetic Minor SIC: 3272/Concrete Products,Nec Permit Status Active NAICS: 32739/Other Concrete Product Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Benji Atkinson Mike Poteat Mike Poteat Maintenance Manager Site Manager Site Manager (910)434-3848 (704)848-4141 (704)848-4141 Compliance Data Comments: Inspection Date 07/07/2021 Inspector's Name Mike Thomas Inspector's Signature: Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signature: Inspection Result Compliance Z/ Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2015 3.07 --- 0.7900 0.0400 0.6600 0.9800 28.30 2010 0.4400 0.0100 0.8800 0.0500 0.7400 0.2300 31.49 *Highest HAP Emitted in pounds Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 04/21/2017 NOV/NRE 2D .0521 Control of Visible Emissions 05/05/2017 Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested 1) Directions From FRO,head south on Green St toward Maiden Ln. At the traffic circle,take the 2nd exit onto Gillespie St. Turn right onto W Russell St. Turn left onto Robeson St. Use the left 2 lanes to turn left onto Raeford Rd and continue for 10 miles. Just past Wagram,turn right onto Old Wire Road(NC Hwy 144).Turn right onto Old Wire Road(Hwy 144)and go—11 1/2 miles to Laurel Hill.Turn right onto US 74 West and continue for 25 miles until you enter Anson County,just after crossing the Pee Dee River. Go—5 more miles to Hailey's Ferry Road(crossroads SR 1801),where there is a large antique cart in a yard on the right and a sign for Welika Fish Camp on the left.Turn left, go almost.2 mile,and then just before the railroad tracks,take a left onto facility's dirt drive.Main office is on the right. 2) Safety Considerations Standard DAQ safety equipment, including vest. Watch for forklifts and truck traffic throughout the whole facility during inspection. Stairs and ladders are slippery because of cement dust 3) Facility and Process Description Adams is a mineral mixing and packaging facility that primarily manufactures bagged concrete. It also produces play sand,all-purpose sand, and mortar. The processing plant is on contiguous property with the W. R.Bonsal mine. Raw materials are delivered on site,processed and dried through the sand and gravel dryer and stored in designated silos. They are then blended and packaged/bagged according to the specified concrete mix and customer. The company has 20 employees(including drivers)and operates 6AM—2:30PM Mon-Fri,40 hrs/wk, 52 wks/yr. 4) Permitted Emission Sources =� � 3l �i ��� -, m= }"'";v s�;,:v>s, y��:,r t r�^.."^" `�"� � u'k. �• � �try ���-eau k;- 5� "�' Drying Operation,consisting of, Natural gas/No.2 fuel oil-fired (15 mmBtu max heat input)sand Bagfilter ES30 and gravel dryer(50 tons per hour BH1A (3,825 square feet of filter area)' maximum capacity). Operating with 0%VE Production Line 1,consisting of: SF22 Portland cement silo,Line 1 BH22 Bagfilter Operating with 0%VE (156 square feet of filter area) SF23 Recycled cement silo,Line 1 BH23 Bagfilter 'Operating with 0%VE (156 square feet of filter area) SF24 Fly ash silo,Line 1 BH24 Bagfilter Operating with 0%VE (156 square feet of filter area) SF25 No-mix cement silo,Line 1 BH25 Bagfilter Operating with 0%VE (156 square feet of filter area) Rock and sand bucket conveyor ES03 operation including a rock silo and BH1A Bagfilter a sand silo (3,825 square feet of filter area)' Operating with 0%VE Cement handling operation ES01 (bagging,weighing,mixing),Line BHO1 Bagfilter 1 (3,840 square feet of filter area); Operating with 0%VE ..._.._._..........................._...... Production Line 2,consisting of: 40-ton capacity Portland cement Bagfilter SF40 silo,Line 2 BH40 (156 square feet of filter area) Operating with 0%VE 80-ton capacity Portland cement Bagfilter SF80 silo,Line 2 BV80 (264 square feet of filter area) Operating with 0%VE 145-ton capacity Portland cement Bagfilter SF 145 silo,Line 2 BV 145 (264 square feet of filter area) Operating with 0%VE SF41 Rock silo,Line 2 BH41 Bagfilter Operating with 0%VE (156 square feet of filter area) SF42 Sand silo split,Line 2 BH42 Bagfilter Operating with 0%VE (156 square feet of filter area) SF43 Fly ash silo,Line 2 BH43 Bagfilter Operating with 0%VE (156 square feet of filter area) SF44 Type S cement silo,Line 2 BH44 Bagfilter Operating with 0%VE (156 square feet of filter area) SF52 Recycled cement silo,Line 2 BH52 Bagfilter Operating with 0%VE (156 square feet of filter area) ES18 Rock screen from sand,Line 2 BH13 Bagfilter Not operating (1,200 square feet of filter area)' Cement handling operation ES02 (bagging,weighing,mixing),Line BH02 Bagfilter 2 (1,900 square feet of filter are) Operating with 0%VE 5) Inspection Conference On 7 July 2021,I Mike Thomas of FRO DAQ conducted a compliance evaluation inspection of the Adams Old Castle Company—Lilesville facility. Prior to entering the facility,I stopped just past the entrance to the plant to observe emissions coming from the plant. My vantage point was not appropriate for a Method 9,but I did not observe any emissions. I met with Mike Poteat,Plant Manager and Benji Atkinson,Maintenance Manager. We met and discussed the following: a) Mr.Atkinson inquired as to why they were getting inspected again so soon(referring to the site visit made by Jeff Cole of FRO on 21 May 2021 for V.E. issues). I explained that I was conducting a full compliance inspection and that Mr. Cole was there for a specific concern regarding the visible emissions he observed as he was driving by. Mr. Atkinson stated that he would show me the places that they were having issues that Mr. Cole observed. b) Verified the FACFINDER information: no changes are needed. c) We reviewed the facility's maintenance and inspection logbooks. Records appeared to be complete and up to date. d) Production: 2020 73,406,722 121104,401 145598,494 11.582.071 2019 6030163114 _T 18,4215170 135271,033 85814,654 [N18 59,091,060 593091,060 6,523,300 [2017 52,416,000 314070,000 - 18,0005000 2016 52,4165000 33407,000 - 1890005000 2015 25,13 8,000 - 8517600 754425000 2014 243015,260 45574,860 - 662,280 2013 19,429,672 - - - 2012 6) Inspection Tour Mr.Atkinson and Mr.Poteat led me on a tour of the facility which was operating. They led me to the areas where they were having problems when Mr.Cole conducted his site visit and pointed out where he had concerns. Mr.Atkinson went on to say that they had replaced seals in several.bin vents and on the lid to the bagfilter. Mr.Atkinson informed me that the facility was continuing to use the Hi-Vac system that was installed to manage dust and clean up in the bagging area. The Hi-Vac unit does not vent outside of the building it is housed in. I was then led to the flyash and cement silos where a truck was unloading cement.Mr. Poteat stated that they discovered a few months ago that drivers bringing in flyash and cement that are not Adams an Oldcastle Company employees were pumping at too high a rate and were clogging and or blowing out the bagfilter system. Since that discovery,drivers are now monitored while they are off loading to insure that they do not exceed 10 to 12 psi. The driver I observed was pumping at 12 psi. 7) Permit Stipulations a) A.2 15A NCAC 2D .0202 &2Q.0304-PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT-The facility shall submit a permit renewal request and a completed air emissions inventory at least 90 days prior to permit expiration. APPEARED IN COMPLIANCE—The facility submitted their emissions inventory on 18 January 2017 and the permit renewal on 23 January 2017,before the required deadline. The facility's next deadline for submittal will be December 2024 for the 2023 calendar year. b) A.3 15A NCAC 2D.0515 PARTICULATE CONTROL REQUIREMENT—Particulate matter emissions from sources shall not exceed the allowable rates as defined in the permit. 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) A.415A NCAC 2D.0516 SULFUR DIOXIDE CONTROL REQUIREMENT—S02 emissions from the combustion sources shall not exceed 2.3 lbs/mm Btu. APPEARED IN COMPLIANCE—The AP-42 emissions factor for No. 2 fuel oil is 0.002 lbs/mmBtu; natural gas is 0.001 lbs/mmBtu. Facility is only burning natural gas. d) A.5 15A NCAC 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENT—Visible emissions from the emission sources shall not exceed 20% opacity. APPEARED IN COMPLIANCE—I observed no VE from any sources during the inspection. e) A.6 15A NCAC 2D .0535"NOTIFICATION REQUIREMENT"—The facility shall notify the DAQ if there are excess emissions that last for more than four hours due to malfunction,breakdown of equipment, or other abnormal conditions. APPEARED IN COMPLIANCE—Mr.Atkinson stated that there had not been any excess emissions that lasted more than 4 hours since the last inspection. f) A.7 15A NCAC 2D .0540 FUGITIVE DUST CONTROL REQUIREMENT- "Particulates from Fugitive Dust Emission Sources," 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—I observed no excess fugitive dust emissions during my inspection. The roads are gravel/sand. Mr.Atkinson stated that he has not received any dust complaints and FRO has not received any dust complaints regarding this facility. g) A.8 15A NCAC 2D.0611 BAGFILTER REQUIREMENTS—Particulate matter emissions shall be controlled as described in the permitted equipment list,the permittee shall perform, at a minimum, an annual internal inspection of each particulate collection system. The permittee shall also perform periodic inspections and maintenance as recommended by the equipment manufacturer. The results of all inspections maintenance activities shall be recorded in the logbook and kept onsite. APPEARED IN COMPLIANCE—Separate logbooks are kept for each bagfilter system. An outside company,Filter Kleen Environmental Service conducts monthly internal inspections and provides any maintenance or repairs that are needed at that time. The most recent internal inspection took place on 8 June 2020. Note: any of these monthly inspections appear to satisfy the annual internal inspection requirement. All entries appeared to be up to date and complete. h) A.9 15A NCAC 2Q.0315 LIMITATION TO AVOID 15A NCAC 2Q.0501(Title V)-Pursuant to 15A NCAC 2Q .0315 "Synthetic Minor Facilities," facility-wide PMIo emissions shall be less than 100 tons per consecutive 12-month period. Facility complies with this limitation by properly operating and maintaining their bagfilters and record keeping in accordance with 15A NCAC 2D .0611 BAGFILTER REQUIREMENTS. APPEARED IN COMPLIANCE—Facility met the requirements by performing the required inspections, maintenance, and record keeping as prescribed in 15A NCAC 2D .0611 BAGFILTER REQUIREMENTS. See Section 7(g)above. 8) Non-compliance History Since 2010 January 18,2012-NOD Failure to renew Air Permit April 21,2017—NRE for excessive visible emissions. 9) 112R Status This 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). 9) Compliance Statement and Recommendations Adams an Old Castle Company—Lilesville appeared to be in compliance with the conditions in their current air permit on 7 July 2021. Pink Sheet:No comments. /mst