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HomeMy WebLinkAboutAQ_F_1600074_20190613_CMPL_InspRpt NORTH CAROLINA DIVISION OF Wilmington Regional Office AIR QUALITY Slurry Pavers,Inc. NC Facility ID 1600074 Inspection Report County/FIPS:Carteret/031 Date: 06/13/2019 Facility Data Permit Data Slurry Pavers,Inc. Permit 00056/R19 107 Arendell Street Issued I1/9/2018 Morehead City,NC 28557 Expires 10/31/2026 Lat: 34d 43.1000m Long: 76d 42.0510m Class/Status Small SIC: 2951 /Paving Mixtures And Blocks Permit Status Active NAICS: 324121 /Asphalt Paving Mixture and Block Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP David Callahan Phillip Tarsovich David Callahan Plant Manager President Plant Manager (252)222-3332 (252)222-3332 Compliance Data Comments: Facility was found in compliance during the inspection Inspection Date 06/04/2019 Inspector's Name Mark Hedrick Inspector's Signature: Mark Hedrick Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature:6/13/19 On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP SO2 NOX VOC CO PMIO * HAP 2017 4.00 — 2.85 13.72 1.73 4.00 --- 2016 2.96 --- 4.16 9.91 2.46 2.96 --- Highest HAP Emitted inpounds) Five Year Violation History:None Date Letter Tyne Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested Full Compliance Inspection 6/4/19 Slurry Pavers Compliance Inspection 6/4/19 Page 2 of 7 General Facility Summary The facility can be reached by taking Hwy. 70 through Morehead City. Before taking the bridge to Beaufort, veer right into the State Ports. The plant is on the right; the office is by the parking lot. An escort is now required to drive onto the port. In addition to standard safety gear, long sleeves are required here. The facility used to have a permitted roofing operation in another building. That process shutdown around 1996. The facility classification has oust changed from Title V to Small,with no reporting requirements. The facility has been repairing and rebuilding since being bought from the previous owners in 2010, and only began asphalt storage and distribution in January 2013. Now, they are only being used as an asphalt distribution terminal with no processing. On March 10,2014, they switched their primary fuel from ultra- low sulfur No. 2 fuel oil to LP (propane) gas. Zero visible emissions were observed for all emission sources, and all required recordkeeping requirements are being met. Consider this facility as being in compliance with all NCDAO regulations. The facility now has the following permitted equipment: Emission Emission Source Control Control System Source ID Description System ID Description One natural gas/No.2 fuel oil- fired boiler(20.9 million Btu EU 1.1 per hour maximum heat input N/A N/A capacity) EU 2.1 storage tank No. 1 (115,646 N/A N/A gallon capacity) EU 2.2 storage tank No. 2 (1,137,822 N/A N/A gallon capacity) EU 2.3 storage tank No. 3 (380,730 N/A N/A gallon capacity) EU 2.4 storage tank No. 4(379,764 N/A N/A gallon capacity) EU 2.5 storage tank No. 6(25,956 F 001 One fiber bed filter(12 gallon capacity) square feet of filter area) EU 2.6 storage tank No. 7(25,956 F 001 One fiber bed filter(12 gallon capacity) square feet of filter area) EU 2.7 storage tank No. 10(19,362 F 002 One fiber bed filter(12 gallon capacity) square feet of filter area) EU 2.8 storage tank No. 15 (1,190,994 F 002 One fiber bed filter(12 gallon capacity) square feet of filter area) EU 2.9 storage tank No. 16(195,342 F 002 One fiber bed filter(12 gallon capacity) square feet of filter area) EU 2.10 storage tank No. 18(195,510 N/A N/A gallon capacity) Slurry Pavers Compliance Inspection 6/4/19 Page 3 of 7 Emission Emission Source Control Control System Source ID Description System ID Description EU 2.11 storage tank No. 19(196,098 N/A N/A gallon capacity) EU 2.12 storage tank No. 20(784,266 N/A N/A gallon capacity) EU 2.13 storage tank No. 21 (580,146 N/A N/A gallon capacity) EU 2.14 storage tank No. 22(25,700 N/A N/A gallon capacity) EU 2.15 storage tank No. 23(27,762 N/A N/A gallon capacity) EU 2.17 storage tank No. 33(20,370 F 003 One fiber bed filter(12 gallon capacity) square feet of filter area) EU 2.18 storage tank No. 34(24,318 F 003 One fiber bed filter(12 gallon capacity) square feet of filter area) EU 5.1 Loading Rack East F 004 One fiber bed filter(75 square feet of filter area) EU 5.2 Loading Rack West F 004 One fiber bed filter(75 square feet of filter area) EU 5.3 Railcar Loading Rack West N/A N/A Facility Saecific Conditions and Limitations A. SPECIFIC CONDITIONS AND LIMITATIONS 1. Any air emission sources or control devices authorized to construct and operate above must be operated and maintained in accordance with the provisions contained herein.The Permittee shall comply with applicable Environmental Management Commission Regulations, including Title 15A North Carolina Administrative Code(NCAC),Subchapter 2D.0202,2D.0503,2D.0515,2D.0516,2D.0521,2D.0535, 2D.0540,2D.1806,and 2Q.0317(6J Avoidance). 2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT-The Permittee,at least 90 days prior to the expiration date of this permit,shall request permit renewal by letter in accordance with 15A NCAC 2Q.0304(d)and(f).Pursuant to 15A NCAC 2Q.0203(i),no permit application fee is required for renewal of an existing air permit(without a modification request).The renewal request(with AA application form)should be submitted to the Regional Supervisor,DAQ.Also,at least 90 days prior to the expiration date of this permit,the Permittee shall submit the air pollution emission inventory report(with Certification Sheet)in accordance with 15A NCAC 2D.0202,pursuant to N.C.General Statute 143 215.65. The report shall be submitted to the Regional Supervisor,DAQ and shall document air pollutants emitted for the 2025 calendar year. Slurry Pavers Compliance Inspection 6/4/19 Page 4 of 7 3. PARTICULATE CONTROL REQUIREMENT-As required by 15A NCAC 2D .0503 "Particulates from Fuel Burning Indirect Heat Exchangers,"particulate matter emissions from the fuel burning indirect heat exchangers shall not exceed the allowable emission rates listed below: Source Emission Limit (lbs/million Btu) One natural gas/cutter stock/No.2,fuel oil-fired boiler(20.9 million Btu per hour 0.49 Ibs/MBw maximum heat input capacity)(EU 1.1) 4. PARTICULATE CONTROL REQUIREMENT-As required by 15A NCAC 213.0515 "Particulates from Miscellaneous Industrial Processes,"particulate matter emissions from Emission Source ID No. EU 1.1 (20.9 million Btu per hour maximum heat input capacity boiler)shall not exceed allowable emission rates. The allowable emission rates are,as defined in 15A NCAC 2D.0515,a function of the process weight rate and shall be determined by the following equation(s),where P is the process throughput rate in tons per hour(tons/hr)and E is the allowable emission rate in pounds per hour(lbs/hr). E=4.10"(P)0.67 for P<30 tons/lu,or E=55 • (P)°r r-40 for P>30 tonsthr. 5. SULFUR DIOXIDE CONTROL REQUIREMENT-As required by 15A NCAC 213.0516"Sulfur Dioxide Emissions from Combustion Sources,"sulfur dioxide emissions from Emission Source ID No.EU-1.1 shall not exceed 2.3 pounds per million Btu heat input. 6. VISIBLE EMISSIONS CONTROL REOUIREMENT-As required by 15A NCAC 2D.0521 "Control of Visible Emissions,"visible emissions from Emission Source ID No.EU 1.1 (20.9 million Btu per hour maximum heat input capacity boiler),manufactured after July 1, 1971,shall not be more than 20 percent opacity when averaged over a six-minute period,except that six-minute periods averaging not more than 87 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour period. However,sources which must comply with a visible emissions standard in 15A NCAC 2D.0524"New Source Performance Standards"or.1110"National Emission Standards for Hazardous Air Pollutants"shall meet that standard instead of the 2D.0521 visible emissions standard. The facility normally burns propane. 0% emissions were observed 7. NOTIFICATION REQUIREMENT-As required by 15A NCAC 2D.0535,the Permittee of a source of excess emissions that last for more than four hours and that results from a malfunction,a breakdown of process or control equipment or any other abnormal conditions,shall: a. Notify the Director or his designee of any such occurrence by 9:00 a.m.Eastern time of the Division's next business day of becoming aware of the occurrence and describe: i. the name and location of the facility, ii. the nature and cause of the malfunction or breakdown, iii. the time when the malfunction or breakdown is first observed, iv. the expected duration, and V. an estimated rate of emissions. Slurry Pavers Compliance Inspection 614119 Page 5 of 7 b. Notify the Director or his designee immediately when the corrective measures have been accomplished. This reporting requirement does not allow the operation of the facility in excess of Environmental Management Commission Regulations. 8. FUGITIVE DUST CONTROL REQUIREMENT-As required by 15A NCAC 2D.0540"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.If substantive complaints are received or excessive fugitive dust emissions from the facility are observed beyond the property boundaries for six minutes in any one hour(using Reference Method 22 in 40 CFR, Appendix A),the owner or operator may be required to submit a fugitive dust plan as described in 2D .0540(f). "Fugitive dust emissions"means particulate matter that does not pass through a process stack or vent and that is generated within plant property boundaries from activities such as:unloading and loading areas, process areas stockpiles,stock pile working,plant parking lots,and plant roads(including access roads and haulroads). No fugitive dust observed. 9. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS-As required by 15A NCAC 213.1806 "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. No odors detected. 10. AVOIDANCE CONDITION FOR AREA SOURCES SUBJECT TO 40 CFR 63 Subpart JJJJJJ(6J1-In accordance with 15A NCAC 2Q.0317,the Permittee is avoiding applicability of 40 CFR 63 Suboart JJJJJJ(6J)"Industrial,Commercial,and Institutional Boilers Area Sources."The Permittee is permitted to operate a natural gas/No.2 fuel oil-fired boiler(ID No.EU 1.1).Per 40 CFR 63.11195(e),this source is exempt from this Subpart because it is defined as a gas-fired boiler in 40 CFR 63.11237.In order to maintain this exemption,the Permittee is allowed to fire liquid fuel only during periods of gas curtailment, gas supply interruptions,startups,or for periodic testing on liquid fuel(periodic testing not to exceed a combined total of 48 hours during any calendar year). a. The Permittee shall maintain records that document the time periods when liquid fuel is fired and the reasons the liquid fuel is fired. b. If the Permittee fires liquid fuel for reasons other than gas curtailment,gas supply interruptions, startups,or for periodic testing on liquid fuel,the Permittee is no longer exempt from Subpart JJJJJJ(6J).As required by 40 CFR 63.11225(g),the Pennittee must provide notice within 30 days of the fuel switch. The notification must identify: i. The name of the owner or operator of the affected source,the location of the source,the boiler(s)that have switched fuels,and the date of the notice. ii. The date upon which the fuel switch occurred. Slurry Pavers Compliance Inspection 6/4/19 Page 6 of 7 As required by 40 CFR 63.11210(h),the Permittee must demonstrate compliance within 180 days of the effective date of the fuel switch. The Boiler ID No. EU 1.1 is a 500 HP Cleaver Brooks was operating during time of inspection burning propane. This boiler runs 2417, between low fire and high firing, as needed They usually shut this boiler down from November through Mid-March (wintertime) as there is no paving of asphalt during this time. No liquid fuel has been burned since T19 issuance. Zero visible emissions were observed for ALL emissions sources facility-wide. Compliance with 2D.0521 was indicated facility-wide for ALL emission sources. Inspection Results The facility had no asphalt processing or storage from 2009 to December 2012. With the T18 permit revision on 6/26/14,the preheaters, converters, and thermal oxidizer have all been removed from the permit. Up until then,they had the equipment to process oxidize the asphalt by bubbling heated air through it,however, that the facility has done no oxidization since 2007; this process occurred in the converters. Beginning January 2013,the facility started as an asphalt storage and distribution terminally only. With the last permit revision, T19, the facility classification went from a Title V facility to a Small facility. The facility now receives asphalt by barge, about 1 to 2 times per year(about 8 million gallons total). They heat the asphalt with the 500 hp Cleaver Brooks boiler only from about March through October(about 280-300 F). The facility converted from No. 2 ultra low sulfur fuel oil to LP gas on 3/10/14,and now burns primarily LP eas. The boiler was operating at the time of inspection burning propane. The boiler is rated for 200 psi steam, but is limited to 150 psi. In the winter months, the asphalt is not heated, yet the temp still maintains about 70-90F. The asphalt is then trucked out only,no railcar loading since 2007. The facility has the following current tank storage: Asphalt in tanks 1, 2, 3, 4, 18, 19, 20, 21, 22 and 23. The facility stores ultra-low sulfur No. 2 fuel oil in Tank 25. All other tanks are empty. No truck Ioadout nor railcar loadout was occurring at the time of inspection. There was no opacity noticed nor objectionable odors detected during the time of inspection. Permit Recordkeepine and Revortine Requirements Most of the facility recordkeeping and reporting requirements in T18 are now gone in T 19. The only recordkeeping requirement now is for 6J avoidance, as follows: AVOIDANCE CONDITION FOR AREA SOURCES SUBJECT TO 40 CFR 63 Subpart JJJJJJ W) In accordance with 15A NCAC 2Q.0317,the Permittee is avoiding applicability of 40 CFR 63 Subpart JJJJJJ(0)"Industrial,Commercial,and Institutional Boilers Area Sources."The Permittee is permitted to operate a natural gas/No.2 fuel oil-fired boiler(ID No.EU 1.1).Per 40 CFR 63.11195(e),this source is exempt from this Subpart because it is defined as a gas-fired boiler in 40 CFR 63.11237.In order to maintain this exemption,the Permittee is allowed to five liquid fuel only during periods of gas curtailment, Slurry Pavers Compliance Inspection b/4/19 Page 7 of 7 gas supply interruptions,startups,or for periodic testing on liquid fuel(periodic testing not to exceed a combined total of 48 hours during any calendar year). a. The Permittee shall maintain records that document the time periods when liquid fuel is fired and the reasons the liquid fuel is fired. b. If the Permittee fires liquid fuel for reasons other than gas curtailment,gas supply interruptions, startups,or for periodic testing on liquid fuel,the Permittee is no longer exempt from Subpart JJJJJJ(0).As required by 40 CFR 63.11225(g),the Permittee must provide notice within 30 days of the fuel switch. The notification must identify: i. The name of the owner or operator of the affected source,the location of the source,the boiler(s)that have switched fuels,and the date of the notice. The date upon which the fuel switch occurred. As required by 40 CFR 63.11210(h),the Permittee must demonstrate compliance within 180 days of the effective date of the fuel switch. The facility has had no liquid fuel burning since issuance of T19. There are now no reporting requirements. Compliance History The facility(SemMaterials, a previous owner) was assessed a civil penalty of$2,000.00 on 07/28/08 for failing to submit their emissions inventory by 06/30/08. The facility(Owens Corning, a previous owner) was assessed a civil penalty of$1,000.00 on 07/20/06 for failing to submit their emissions inventory by 06/30/06. A request for remission was denied on 10/13/06. Note that the current owners, Slurry Pavers, have had no NOW or NODS. Facility Emissions Under T18,the facility had annual emission reporting. Now under T19, emissions will not be reported until 2025. Conclusions, Comments, and Recommendations The facility appeared to be in compliance with their air permit at the time of the inspection.