AQ_F_1700009_20200507_CMPL_InspRpt (4)

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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: 05/08/2020
Facility Data Permit Data
Southside Materials,LLC-Shelton Quarry Permit 03370/R17
1524 Rock Quarry Road Issued 8/8/2014 j
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
NAICS: 212313/Crushed and Broken Granite Mining and Quarrying Current Permit Application(s)None j
Program Applicability
Contact Data g pp y �
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Facility Contact Authorized Contact Technical Contact SIP
Sammy Murphy M.J.O'Brien,Jr. A. Scott Ross NSPS; Subpart 000
Area Manager President Mining Engineer
[phone] [phone] [phone]
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Compliance Data
Comments: PCE due to COVID-19 restrictions.
Inspection Date 05/07/2020
Inspector's Name Blair Palmer
Inspector's Signature: :� , ~"` Operating Status Operating
Compliance Code Compliance-inspection
Action Code PCE
Date of Signature:05/12/2020 MTH On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
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TSP S02 NOX VOC CO PM10 *HAP t
2013 4.20 --- --- --- --- 1.80 ---
2008 5.34 --- --- --- --- 1.93 ---
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*Highest HAP Emitted in ounds
Five Year Violation History:
Date Letter Tyne 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
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PERMITTED EMISSION SOURCES:
Emission Emission Source Control Control System
Source ID Description System ID Description
Non-Metallic Mineral Processing Plant, utilizing water suppression with no other control devices,including:
_ _ _
v een ,. �' N/A
ES Screen Screenm Operations_..... N/ m.. u .. ...... ,
ES-Crush Crushing Operation F N/A_F N/A
ES Convey Conveying Operations �F_N
/A F N/A
INSIGNIFICANT/EXEMPT ACTIVITIES:
( (Source of Tit1e V
Source Exemption Regulation (Source of TAPS? ) pollutants?
! .
IES-Silo-1 65 ton cement silo with ba 21ter 2Q.0102 (c)(2)(E)(i) Yes�F Yes
......... ._..�.— .......�_ ...__.._._ . _... _.... ..._..._ ....___. - ._.
�IES-Weld-1 portable diesel fired welder(32.6 hp) 2Q .0102 (c)(1)(L)(i) Yes � — Yes.___,
DISCUSSION:
On May 5,2020,Mr.Blair Palmer,DAQ-WSRO Environmental Specialist,contacted Mr. Scott Ross,P.E.,Mining
Engineer for Southside Materials,LLC—Shelton Quarry via email for purposes of a PCE due to COVID-19 restrictions. !
Final information and discussion for the PCE was completed on May 7,2020. Mr.Ross included operational data, "Our
crushing in 2018 was roughly 567,000 tons,while 2019 was 650,000 tons(approximately)." The facility was last
inspected with a Full Compliance Evaluation(FCE)by WSRO personnel on May 7, 2019, and it appeared to be operating
in compliance at that time. The facility was also visited by DAQ personnel again on May 21,2019. The facility was
ultimately found in to be operating in violation by WSRO,and a Notice of Violation was issued on June 4,2019. 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 previously verified and are correct in IBEAM.
APPLICABLE REGULATIONS:
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The applicable air quality regulations as listed in Condition A.1 of Air Permit No.03370R17 are: 2D .0202,2D .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:
https://www.msha.gov/mine-data-retrieval-system under MSHA Mine ID No. 3100085. Quarry pit blasting can occur
on occasions.
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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.
57,67,467 (crushed stone)-Also used in the concrete and asphalt industry.
No.4 or 5(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.
Due to COVID-19 restrictions, Mr. Palmer was unable to verify what equipment was in operation. All the plant
operations were in operation or crushing stone during the last DAQ inspection.
The facility's permit exempt sources include IES-Silo-1, a 65-ton cement silo with bagfilter.However,this silo is no
longer used according to Mr. Ross. IES-Weld, a portable diesel-fired welder(32.6 hp)is used on occasions.
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PERMIT CONDITIONS:
Condition A.2 (213 .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.
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,including a revised plant flow diagram i
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 I
included after the June 4, 2019 referenced NOV in this report. Mr.Palmer was emailed by Mr. Ross,the most current
equipment list and flow diagram. There have been no changes since the May 21,2019 DAQ visit. 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(and permit condition A.10), and control process generated emissions
from crushers with wet suppression so that all applicable opacity standards are met. Mr.Palmer was unable to verify any
possible visible emissions from haul roads during this PCE. However,Mr. Ross indicated that that the facility uses water
suppression on the haul roads. According to the last inspection report dated May 7, 2019,the inspector stated,"The wet
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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." Compliance is expected.
Conditions A.6 and A.7 contain the 2D .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. Compliance with these limits could not determined at the time of the PCE,but the last DAQ inspection
yielded no problems based on the inspection report dated May 7,2019. Compliance is likely.
Condition A.9(2D .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 the 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. This information was emailed to Mr.
Palmer on May 7,2020, and the facility appears to meet the requirements. Very few problems were noted to the previous
DAQ inspection.
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 in compliance), all due to discovery during May
7,2019 DAQ inspection. 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 on April 1994 and June 1995. C-7,
originally tested in April 2003,had been removed from the quarry. Conveyors C-17, C-18, C-19,and C-20 were not in use
although listed on the most recent(January 2007)equipment list. C-17 and C-18 were not at the facility. 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 last DAQ inspection, other than the August 8, 2019 NSPS visible emissions testing for
C-8.
Condition A.9 contains the 15A NCAC 2D .0535 rule which requires the permittee to notify the DAQ director of any
excess emissions lasting 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.
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Condition A.10 contains the 15A NCAC 2D .0540 fugitive dust control requirement. Based on the last inspection report,
"The inspector did not observe any fugitive dust emissions traveling beyond the property boundaries. The facility was
using a water truck on the grounds during the inspection." 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:
`s Pollu ant CYz OI =Actual mission P,,ote" 'itnn�ssion� ons/Y ar) �
2 a °�� ' t §�
Fr.Ke. ... . ., _..
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PM 4.2 45.678
PM10 1.8 17.287
PM2.5 0.7 3.7
Arsenic 0 4.643 e-07
Beryllium 0 5.322e-08
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Total Chromium 0 3.175e-06 }
Lead 0 1.193e-06
Manganese 0 1.281e-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.
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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.
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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
for Nonmetallic 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.
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PERMIT DISCUSSION:
• IES-Silo-1 - 65-ton cement silo with bagfilter is no longer used.
• The IES-Weld-1 -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 May 7,2020 PCE.
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