AQ_F_0400045_20200910_CMPL_InspRpt

NORTH CAROLINA DIVISION OF FFayevle Regional Office
AIR QUALITY eady Mix,LLC
ty ID 0400045
Inspection Report PS: Anson/007
Date: 09/10/2020
Facility Data Permit Data
Hildreth Ready Mix,LLC 08715/G04
878 City Pond Road- SR 1142 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
NAILS: 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
[phone] [phone] [phone]
Compliance Data
Comments: q
Inspection Date09/10/2020
r�� � Inspector's Name Mike Turner
Inspector's Signature: y` Operating Status Operating
Compliance Code Compliance-inspection
�G'' Action Code FCE
Date of Signature: 0 0>D On-Site Inspection Result Deficiency
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2017 1.25 --- --- --- --- 0.3800 0.1130
2012 0.7200 --- --- --- 0.2200 0.0610
*Highest HAP Emitted(inpounds)
Five Year Violation History:
Date Letter Tyne 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 TO SITE:
From FRO take Green Street to Gillespie and merge onto 195 BUS/301 S. Merge onto 301 S.,then take a
right onto NC 71. Continue to follow signs for NC 71. Merge onto HWY 74 W. and continue for 49 miles
to Wadesboro.In Wadesboro,take Hwy 742 south for 3.5 miles to City Pond Road and turn right. Hildreth
Ready Mix is approximately 2 miles on the right. 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. Most of Mr.
Hildreth's business now is delivering concrete from his batch plant, which is operated on an"as needed"
basis.
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.
INSIGNIFICAN$�T/EXEMPyyT ACTIVITIES:
IN lip
HOW
1-1 2Q.0102 (h)(5) No W Yes
Sand and Aggregate Handling
Facility was not operating during the inspection.
V. INSPECTION CONFERENCE:
On 10 September 2020, 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 the owner,Karl Hildreth.
We discussed the following:
a) Mr.Hildreth verified the FACFMER information: no changes are needed.
b) I viewed the maintenance logbook,which lacked key reporting requirements. See compliance
statement under stipulation F,"Fabric Filter Requirement".

c) Production:
Operating hours As needed
Employees 2 including drivers
Production(cu yd) 2019: 1,106
2018: 6,746
2017: 6,294.5
2016: 4,147
2015: 7,972.5
2014: 6,000
2013: 2,000
2012: 3,397
VI. INSPECTION SUMMARY:
Due to the facility not operating I was limited to inspecting the areas around the plant and bagfilter for signs
of excessive emissions. Though the batch plant is old,I did not see any compromises in the ductwork or
any indicators of excessive emissions.Mr. Hildreth stated he conducts all silo fills,to ensure they are done
most efficiently and so pressures do not exceed 8psi.Mr. Hildreth stated this facility has not added any new
equipment, nor have there been any process changes at this facility.
VII. APPLICABLE AIR QUALITY REGULATIONS:
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—PARTICULATES FROM MISC.INDUSTRIAL PROCESSES—
Particulate emissions shall not exceed allowable emission rates.
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—CONTROL OF VISIBLE EMISSIONS—Visible emissions shall not exceed
20%opacity.
APPEARED IN COMPLIANCE: The facility was not operating during the inspection. I did not see
any indication of issues with visible emissions at the time of inspection.
D. 15A NCAC 2D .0535—NOTIFICATION REQUIREMENT—Notify DAQ in the event of excess
emissions lasting longer than 4 hours resulting from malfunctions,breakdowns, or abnormal
conditions.
APPEARED IN COMPLIANCE: Mr. Hildreth stated that there had not been any operational
exceedances that would have required notification to this office.

E. 15A NCAC 2D .0540—PARTICULATES FROM FUGITIVE DUST EMISSION SOURCES—
Fugitive dust emissions shall not contribute to substantive complaints, or excessive dust emissions
beyond the property boundary.
APPEARED IN COMPLIANCE: No fugitive dust concerns at the property boundaries were noted
during the inspection.Mr.Hildreth stated that they have not received any dust complaints,nor has FRO
DAQ received any complaints about this facility.
F. 15A NCAC 2D .0611 —FABRIC FILTER REQUIREMENT—Particulate emissions controlled by
fabric filters; annual internal inspections; record keeping.
DEFICIENCYNOTED: The maintenance logbook contained only the dates inspections were
completed,with no records of what inspections or maintenance were performed,no records of what
problems or malfunctions may have occurred,no record of corrective actions that may have been taken
to fix an issue with the bagfilter, or who performed the maintenance or inspection. Mr. Hildreth
performs the maintenance himself. Mr. Hildreth stated that he removes the bags, inspects them for
damage, rinses them, and lets them dry before reinstalling them.
Mr.Hildreth's records show periodic I&M during 2017,2018 &2019,but nothing from 9 August 2019
to 8 September 2020, leaving more than 12 months between annual internal inspections. This
constitutes another deviation from his permit and the Fabric Filter Requirement.
G. 15A NCAC 2D .1104—TOXIC AIR POLLUTANT CONTROL REQUIREMENTS—Arsenic
emissions shall not exceed the AAL. Concrete production limit based on distance to property boundary
(340,500 cubic yards at 75 feet),which shall be marked. Monthly recordkeeping.Notification of
changes. Annual reporting.
H.
APPEARED INCOMPLIANCE: Mr.Hildreth showed me the nearest property boundary,which does
appear to be—75' from the emission source. The nearest property boundary limits the facility to
340,500 cubic yards of production annually, and the 1,106 cubic yards of concrete this facility
produced in 2019 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 138 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 appears 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 facility's
maximum throughput is 100 cubic yards per hour;which is much less than the maximum permitted
throughput, and the annual throughput, 1,106 cubic yards in 2019, is also much less than the 340,500
cubic yard limit.
J. 15A NCAC 2Q.0711—TOXIC AIR POLLUTANT EMISSION LIMITATIONS—Emissions of
toxic air pollutants shall not exceed the listed limitations without first obtaining a permit and
demonstrating compliance with 2D .1100.

APPEARED INCOMPLIANCE. 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.
VHI. NON-COMPLIANCE HISTORY SINCE 2010:
03/25/18 NOV issued for late annual reporting.
03/21/17 NOV issued for late annual reporting.
03/28/16 NOD issued for late annual reporting.
05/28/10 NOV issued for late annual reporting.
IX. RISK MANAGEMENT (112r):
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).
X. CONCLUSION AND RECOMMENDATIONS:
On 10 September 2020,Hildreth Ready Mix,LLC appeared to be operating IN COMPLIANCE with their
current air quality permit,with the exception of the deficiencies noted above in the"Fabric Filter
Requirement".I recommend Hildreth Ready Mix,LLC receive a Notice of Deficiency letter to document
these deviations from their air quality permit.
PINK SHEET ADDITIONS:
None.
/wrm