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HomeMy WebLinkAboutAQ_F_1700009_20201120_CMPL_InspRpt (4) NORTH CAROLINA DIVISION OF Winston-Salem Regional Office AIR QUALITY Southside Materials,LLC-Shelton.Quarry NC Facility ID 1700009 Inspection Report - County/FIPS: Caswell/033 Date: 11/30/2020 - Facility Data Permit Data Southside Materials,LLC- Shelton Quarry Permit 03370/R17 1524 Rock Quarry Road Issued 8/8/2014 Pelham,NC 27311 Expires " 7/31/2022 Lat: 36d 32.1480m Long: 79d 27.6000m Class/Status .Small SIC: 1423/Crushed And Broken Granite Permit Status Active NAILS: 212313/Crushed and Broken Granite Mining and Quarrying Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Jimmy Raines M. J. O'Brien,Jr. A.Scott Ross NSPS: Subpart 000 Plant Manager President Mining Engineer (424)770-3505 (540)674-5556 (540)674-5556 Compliance Data Comments: FCE during COVID-19. Inspection Date 11/20/2020 Inspector's Name_Blair Palmer Operating Status Operating Inspector's Signature: �� '� P g P g Compliance Code Compliance-inspection Action Code FCE Date of Signature:l2/1/2020 MTH On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP._ S02 NOX VOC _CO PM10 *HAP 2013 4.20 --- -- --- --- 1.80 --- 2008 5:34 --- --- --- --- 1.93 --- Highest HAP Emitted inpounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 06/04/2019 NOV 2D.0501 Compliance with Emission Control Standards 09/30/2019 06/04/2019 NOV Part 60-NSPS Subpart 000 Nonmetallic Mineral 08/08/2019 Processing Plants Performed Stack Tests since last FCE: Date Test Results Test Method(s) Source(s)Tested 08/08/2019 Compliance Method 9 C-8 1 , ii PERMITTED EMISSION SOURCES: Emission Emission Source Source ID Control Control System Description System 11 Description Non-Metallic Mineral Processing'Plant,utilizing water suppression with no other control devices,including: _..._— _.�...� � �._..�: _._...�.w. �.�:. __:�..:. _..� _.,_...� .....,�_ ES-Screen Screenmg Operations ( N/A N/A ... ....: ......... {{ ES-Crush lCrushing Operation N/A N/A F ES-Convey [Conveying Operations N/A N/A INSIGNIFICANT/EXEMPT ACTIVITIES: Source Exemption Regulation Source of TAPS? Source of Title V Pollutants? IES-Silo-I - 65 ton cement silo with bagfilter F 2Q .0102 (c)(2)(E)(i) F Yes Yes J [I -Weld-1 -portable diesel-fired welder(32.6 hp) 2Q .0102 (c)(1)(L)(ii) Yes ,.......w... Yes DISCUSSION: On November 20, 2020,Mr. Blair Palmer,DAQ-WSRO Environmental Specialist Il, contacted Mr.Jimmy Raines,Plant Manager for Southside Materials,LLC-Shelton Quarry for the purpose of a Full Compliance Evaluation(FCE)due to COVID-19.restrictions. Mr.Palmer inquired prior to the evaluation for status of any possible COVID-19 cases at the facility. Based on the facility's response,Mr. Palmer proceeded with the evaluation,while following all updated CDC guidance and the June 12,'2020 DAQ Re-Entry plan. The facility was last inspected with a Partial Compliance Evaluation (PCE)by WSRO personnel on May 7,2020, and it appeared to be operating in compliance at that time. Shelton Quarry' crushes various size stone,which is used for various purposes, such as road construction. The facility is open for business Monday-Friday, 8-10 hours/day,and 51`weeks/year at the present time. It is not recommended for DAQ personnel to conduct inspections during very cold weather,especially if there is or recently have been ambient air temperatures at or below 32 degrees Fahrenheit because the plant relies on water for the crushing operations. Latitude and Longitude coordinates have been prev iouslyverified in the IBEAM database. Mr. Jimmy Raines is now the facility contact for IBEAM purposes and future DAQ evaluations or inspections. This change has been made in IBEAM after the November 20, 2020 evaluation. APPLICABLE REGULATIONS: The applicable air quality regulations as listed in Condition A.1 of Air Permit No. 03370R17 are: 2D .0202,21);.0501,2D .0510,2D .0521, .0524(40,CFR 60 Subpart 000), 2D .0535,2D .0540,2D .1806, and 2Q .0309. This permitted facility is not required to implement a Section 112(r)risk management plan under the federal regulation 40 CFR 68, because they do not produce, use, or store any of the regulated chemicals in quantities above the threshold limits. However,the General Duty Clause contained in this rule applies to all facilities and requires the safe and responsible handling of hazardous materials in any quantity. SAFETY: A safety vest, shoes, and eyewear are required at the plant. Mr. Palmer searched this quarry(MSHA Mine ID: 3100085) under the Mine Data Retrieval System(MDRS),as part of the Mine Safety and Health Administration(MSHA), for any on-site accidents within the past four years. None were found. All of the data can be accessed here: 2 https://www.mslla.gov/mine-data-retrieval-system under MSHA Mine ID No. 3100085. Quarry pit blasting can occur on occasions. PROCESS AND INSPECTION: The process begins with holes being drilled into the quarry walls,usually in a vertical axis. After holes are drilled,a mixture of ammonium nitrate and other material is ignited with blasting caps causing an explosion, causing rock to break into pieces of various sizes,which fall mainly into the quarry floor and/or roads leading into and out of the quarry. The loose rock is then picked up by approximately 50-ton front end loaders and placed into piles known in the industry as "Muck Piles," The piles are occasionally watered by the facility's water truck to prevent fugitive dust,before being transported by 50-70-ton dump trucks and offloaded into the dump hopper and associated feeder. The rock is then fed into the primary jaw crusher and then routed to the remaining circuit of various conveyors, screens, and secondary crushers. The crushed pieces of rock eventually are stock piled into different diameter stone. Some RIP-RAP is also made at this location. The following are the examples of stone crushed at this location: 78M(crushed stone)-Used.in the asphalt and concrete industry. 57, 67, (crushed stone)- Also used in the concrete and asphalt industry. No. 4,5, and 66 (crushed stone) Used or placed around septic tank drainage(nitrification) lines Aggregate Base Course(ABC) Crushed stone used for road bases,building pads; residential driveways, and some parking lots. Most the plant operations were in operation or crushing stone during the DAQ inspection, The exceptions were as follows: CS-11,CS-12,and B-11. FH-01,C-17,and C-18,which are part of the portable plant operations,were also not in operation. The plant;was operating at 600 tons/hr and primary jaw.crushing setting of six inches. The facility's permit exempt sources include IES-Silo-1, a 65-ton cement silo with bagfilter. However;this silo is no. longer used and has not been in several years. IES-Weld, a portable diesel-fired welder(32.6 hp)is used on occasions. PERMIT CONDITIONS: Condition A.2(21) .0202)deals with"Registration of Air Pollution Sources; The permit for this facility expires on July 31,2022, At least 90 days prior to the expiration of this permit,the Permittee shall submit a permit renewal and an emissions inventory for the 2021 calendar year. The facility will be inspected at least once before the expiration date. Compliance can be anticipated. Mr. Palmer briefly went over the requirements with Mn Raines. Condition A.3 contains the 15A NCAC 2D .0501(c)equipment reporting requirement. This condition requires this facility to maintain an on-site equipment list and plant flow diagram of all equipment covered under this permit. This list must include the rated crushing capacity of all crushers,width of belt conveyers, dimensions and configurations of screens,the rated capacity of all other equipment not exempt from permitting,dates of equipment manufacture,dates of required NSPS testing,and must bear the date of last revision. This condition also requires the permittee to provide a 15- day written notification to the Regional Supervisor of the Division of Air Quality, in eluding a revised plantflow diagram and equipment list, any time the permittee installs new non-primary crushing equipment or relocates existing non-primary crushing equipment.A current equipment list and flow diagram that adhere to the requirements of this condition were included after the June 4, 2019 Notice of Violation(see compliance history section of this report), Mr. Palmer was emailed by Mr. Ross,the most current(July 2019)equipment list andflow diagram during the May 7,2020 PCE. There have been no changes since then. Compliance with this condition and 2Q 0501(c) is demonstrated. Condition A.4 contains the 15A NCAC 2D .0510, "Particulate Control Requirement." This condition requires the - permittee to not produce materials in such a manner that PM, PMio, and total suspended particle ambient air quality standards are exceeded beyond the property boundary. Additionally,the facility is required to control fugitive dust emissions as required by 15A NCAC 2D .0540(Condition A.10), and control process generated emissions from crushers - 3 - with wet suppression so that all applicable opacity standards are met. Mr.Palmer did not notice any fugitive emissions. The facility uses a water truck as necessary according to Mr.Raines. According to the DAQ inspection report dated May 7,2019,the inspector stated,"The wet suppression systems were in use during the inspection and were observed to be operating effectively-compliance with this condition can is probable at this time." Based on all information,compliance is likely at this time. Condition A.5 contains the requirements for the primary crusher specifications. The primary jaw crusher is rated at a maximum 650 tons per hour with a 10-inch diameter setting.',The crusher generally operates at a 6.7" setting and has an average throughput of less than 500 tons per hour,usually 450 tons per hour. The facility must submit a permit application for any changes to the crusher that are not considered"like-for-like." As noted earlier,the plant was operating at 600 tons/hour and a jaw crusher setting of 6 inches. Compliance is expected. Conditions A.6 and A.7 contain the2D .0521 visible emissions control requirement.This condition limits sources to 20 percent or 40 percent opacity depending on manufacture date. 'It should be noted that 40 CFR Part 60;:Subpart 000 limits many of these sources to more stringent visible emissions standards than the limits listed in 2D .0521 and is discussed below. Mr. Palmer observed no visible emissions from the subject equipment, indicating likely compliance. Condition A.8 (21) .0524,40 CFR 60, Subpart 000)concerns"New Source Performance Standards." The facility is required to notify the Division in writing no later than thirty days after the commencement of construction of a crusher, screen or conveyor except in the case of mass-produced sources,and to report again within fifteen days after the initial startup of the affected source. Additionally,this condition limits the visible emissions from these affected sources to 15% opacity for crushers, 10%opacity for the conveyors and screens,and 0%`opacity for:conveyors and screens that process saturated materials. A rule change for this subpart requires affected sources constructed after April 22 2008,to comply with the more stringent visible emissions limits of 12%opacity for crushers and 7%opacity for conveyors and screens. For affected sources that use wet suppression and were installed after April 22,2008,this condition requires monthly inspections of water systems and spray nozzles to be recorded in a logbook. The facility is required to conduct performance testing on any affected source within sixty,days of achieving maximum production but no later than 180 days after he initial startup. A testing protocol must be submitted to the Division at least 45 days prior to testing and at least 15 days advance written notice must be afforded the Division to provide an observer. This facility is also required under Condition A.9 to perform monthly periodic inspections to check that water is flowing to discharge nozzles on wet suppression systems for sources that were constructed on or after April 22,2008. The facility currently does not have any subject equipment on or after this date, but the plant performs'daily'inspections regardless and records findings. Compliance is indicated. The conveyor'list and process usage were also reviewed for NSPS compliance. Conveyor C-8 manufactured in 2006 is the latest equipment that was tested on August 8,2019(and determined to be in compliance),all due to discovery during' the May 7 and 21,2019 DAQ inspections. The facility did not have C-8 tested previously, but it was tested on August 8, 2019. The following was borrowed by Mr.Bryant's May 7,2019 inspection report: "Conveyors C-02 and C-15 are subject to Subpart 000 but were previously tested in April 1994 and June 1995. C-7, originally tested in April 2003,had been removed from the quarry. Conveyors C-11, C-12`were not is use during the inspection. C-17 and C-18 were not in use. C-19 and C-20 were on-site and not being used. Mr.Raines.stated that these two conveyors'were intended for a project that never materialized." There have no other changes since the last PCE on May 7, 2020. Condition A.9 contains the 15A NCAC 2D .0535 rule which requires the permittee to notify the DAQ director of any excess emissions fasting longer than four hours resulting from a malfunction,a breakdown of process or control equipment or any other abnormal conditions. Mr. Ross indicated that no such incidents had occurred,and no reports have been received. Compliance is expected. 4 Condition A.10 contains the 15A NCAC 2D .0540 fugitive dust control requirement. Mr. Palmer did not observe any dust problems during the inspection or evaluation. Mr. Raines commented that a designated water truck is used when necessary. Water is used from either lower pit area and/or pumped into a holding pond. Compliance with the condition is likely. Condition A.11 contains the 15A NCAC 2D .1806 control of odorous emissions requirement. No objectionable odors around the facility boundary were noted during the last inspection. There have been no complaints regarding odors at the facility. Compliance with the condition can be expected. Condition A.12 pertains to"Permit Reopening." There is currently no reason to have the DAQ director modify and reissue the current permit. There have been no credible air emissions data and/or dispersion modeling not previously considered during the permit application process.Compliance is indicated. FACILITY WIDE EMISSIONS: As referenced in the latest permit renewal R17 (Davis Murphy,Environmental Engineer/Permit Coordinator 08/08/2014) and based on emissions from calendar year 2013,the facility-wide potential and actual emissions are listed in the table below: Pol 3 R� _ r e CIS 20>l3 ROM tnyss�ans , x t Poteait'�atl Emus" i,o sz(Tons year) �.eS.. •.-. .�. .,. v i ..,., `�O,1s„/Y� ' ,z..'�;t'�.., €.fir;_.. .,,.". ... .. �.:k Aa.�,. PM 4.2 45.678 :PM10 1.8 17.287 PM2.5 0.7 3.7 .;Arsenic 0 4.643e-07 V}Beryllium 0 5.322e-08 ;Total Chromium 0 3.175e-06 Lead 0 1.193e-06 Manganese 0 1.281 e-05 Nickel 0 4.577e-06 As mentioned earlier,the facility crushed approximately 567,000 tons of rock in CY 2018 and 650,000 tons in CY 2019. The above emissions appear to be reasonable. MACT/GACT: The facility does not have an emergency generator at the current time. The facility has no gasoline tanks,thus no gasoline dispensing equipment. L COMPLIANCE HISTORY(within last five years): A Notice of Violation(NOV)was issued June 4,2019 for failure to comply with the requirements associated with 15A 2D .0501(c), specifically not maintaining on-site an updated equipment list and plant flow diagram of all equipment covered under this permit. Also the facility was found in violation of 40 CFR Part 60,Subpart 000 "Standards of Performance forNonmetallic Mineral Processing Plants,"and 15A NCAC 2D .0524, for failure to report the actual date of initial start- up and conduct performance testing on Conveyor C-8. Testing was completed on August 8,2019,and a WSRO-DAQ letter was sent to the facility on September 23, 2019 indicating compliance. 5 PERMIT DISCUSSION: • IES-Silo-1 65-ton cement silo with bagfilter is no longer used. • The IES-Weld-I-portable.diesel-fired welder(32.6 hp)should reflect the most current permit exemption due to 2016 DAQ rule changes. CONCLUSION: Based on records'and phone conversation with plant personnel,this facility appeared to be operating in compliance with Air Quality standards and regulations at the time of the November 20, 2020 FCE. i 6