AQ_F_1700009_20190507_CMPL_InspRpt (3)

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: 05/07/2019
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
NAICS: 212313 /Crushed and Broken Granite Mining and Quarrying Current Permit Application(s)None
Contact Data Program Applicability
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
(336)388-56 13 [phone] [phone]
Compliance Data
Comments:
Inspection Date 05/07/2019
Inspector's Name Chris Bryant
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: tO ( MTH On-Site Inspection Result Violation
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:None
Date Letter Tvne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE: None
Date Test Results Test Methods) Source(sl Tested
Permitted Emission Sources:
Emission Emission Source Control Control System
Source ID Description System 11) Description
Non-Metallic Mineral Processing Plant, utilizing water suppression with no other control devices, including:
ES-Screen Screening Operations N/A N/A
ES-Crush Crushing Operation N/A N/A
r__
ES-Convey Conveying Operations N/A �� N/A
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Insignificant/Exempt Activities:
Source of Title V
Source Exemption Regulation Source of TAPs? pollutants?
!IES-Silo-I - 65 ton cement silo with bagfilter 2Q .0102 (c)(2)(E)(i) Yes Yes
--- -
ilES-Weld-1 - portable diesel-fired welder(32 6 hp) 2Q .0102(c)(1)(L)(ii) I Yes Yes
Introduction
On May 7,2019, Mr. Chris Bryant, Environmental Specialist of the DAQ-WSRO, met with Mr. Jim Raines, Manager at
Southside Materials, LLC-Shelton Quarry for an unannounced targeted compliance inspection. The facility contact,
Sammy Murphy, has been transferred, and the new facility contact is Jim Raines. The technical contact (A. Scott Ross),
authorized contact (M.J. O'Brien), and invoice contact (Sherry Ferguson) are located in Dublin, Virginia and were not
available for the inspection. Mr. Raines was able to take some time to meet with the inspector to discuss the permit
conditions and record keeping requirements. Mr. Raines also provided this inspector with a tour of the quarry grounds
where the crushing, conveying, and screening operations were observed.
On May 21, 2019, Mr. Bryant and DAQ-WSRO Environmental Specialist, TJ Gray, had to make an additional visit to the
meet with Mr. Raines at the quarry to reconcile the crushing and conveying operations as related to Permit Condition A.3
(15A NCAC 2D .0501(c)) and the New Source Performance Standards contained in 15A NCAC 2D .0524 and
promulgated in 40 CFR 60, Subpart 000 for nonmetallic mineral processing equipment. There were some deviations
from the last equipment list and flow diagram versus the current operation processes that required some additional
updated information and a follow-up visit.
The facility was last inspected on August 4, 2017 by multimedia inspector, Jack Kitchen. Mr. Kitchen concluded, based
on review of records and visual observations at that time, that the facility was operating in compliance with all applicable
air quality regulations. The facility has a "flexible permit" as part of NC-DAQ's quarry permitting procedure that was
issued on August 8, 2014, and it will expire on July 31, 2022. Southside Materials, LLC-Shelton Quarry is a crushed
stone quarry that typically operates Monday through Friday from 7:00 am to 4:00 pm and 50 weeks per year. The facility
information has been updated in IBEAM to reflect the change in facility contacts. The facility's technical contact A. Scott
Ross handles permit modifications, equipment changes, reporting, and visible emission testing as required by 40 CFR 60,
Subpart 000 and contained in 15A NCAC 2D. 0524,"New Source Performance Standards."
Safety Equipment
Safety shoes, safety glasses, hearing protection, and a reflective vest are required safety equipment needed when
inspecting this facility. Inspectors should be aware of the heavy equipment and falling debris from the conveyors and
screens. Visitors must sign-in and wear proper safety equipment prior to entering quarry grounds.
Latitude/Longitude Verifications
The latitude and longitude coordinates were verified to be accurate as documented in IBEAM.
Applicable Regulations
According to Permit Condition A.1 the facility is subject to the following regulations: Title 15A North Carolina
Administrative Code(NCAC), Subchapter 2D .0202, 2D .0501, 2D .0510,2D .0521, 2D .0524 (40 CFR 60, Subpart
000), 2D .0535, 2D .0540, 2D .1806, and 2Q .0309. This facility is not subject to RMP requirements of the 1 12(r)
program since it does not use or store any of the regulated chemicals in quantities above the threshold levels in the rule.
The facility is only subject to the General Duty requirements contained in the General Duty Clause.
Discussion
The inspector originally met with Mr.Jim Raines, Manager, at Southside Materials, LLC-Shelton Quarry on May 7, 2019.
At that time, Mr. Raines was somewhat preoccupied with a MSHA inspector but was able to take some time between
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1 1:00 AM-1:00 PM (while the other inspector went to lunch)to review the permit, applicable regulations, and current
operating processes. The facility was issued a new permit on August 8, 2014 that will expire on July 31,2022. The
quarry was issued a"flexible permit"and in doing so must comply with 2D .0501 Emission Control Standards. Permit
Condition A.3 requires the facility to maintain an on-site equipment list and plant flow diagram. The specifics of the
condition will be discussed in the permit condition section below. The condition allows the facility to install/relocate non-
primary crushing equipment if the changes do not change the overall rate capacity. However, the facility must provide
15-day notification(15 days prior for new equipment or within 15 days for existing equipment), including updated list and
diagram, to the DAQ for each of these changes. The last flow diagram and equipment list were dated January 8, 2007,
and some the equipment had been taken off the process lines, replaced, or completely removed from the premises.
The crushers, conveyors, and screens were reviewed and cross-referenced with the information available at the Winston-
Salem Regional Office and with the information provided on-site. The facility did not have a current equipment list or
flow diagram, and the inspector and facility contact had to base the inspection on the January 2007 equipment list, which
was last compiled while the facility was owned by Vulcan Materials. The Southside Materials, LLC corporate office,
located in Dublin, VA was unable to provide an updated list or diagram, but it did help in getting some updated
information in regard to the NSPS requirements for the crushers, conveyors, and screens. As previously stated, Mr.
Bryant and Mr. Gray made a follow-up visit on May 21,2019 in order to finish reconciling the equipment list and NSPS
applicability. The facility had replaced a"short-head"crusher, ID 006 (4-1/4 SH, manufactured prior to 1983)with a 300
HP unit that appears to be a like-for-like replacement. The new crusher was manufactured in November 2005 (Serial
#3031902). During some investigation and communication with Mr. A. Scott Ross(located at the corporate office in
Dublin, VA), it was discovered that the newer crusher was installed at Shelton Quarry in June 2018. Since the crusher
was brought in from the Wytheville, VA site, Mr. Ross was asked to provide testing information, if possible. After the
second inspection, Mr. Ross was able to contact Virginia Department of Environmental Quality and provide a copy of the
air inspection report which dated the visible emission tests as October 3,2009. The test report was approved and signed
on August 9, 2009. The other 3 crushers(Jaw,Omni Std,Omni SH) were previously tested in May 1999, June 1995, and
September 1989, respectively.
The conveyor list and process usage were also reviewed for NSPS compliance. Conveyor C-8, manufactured in 2006, is
subject to 40 CFR 60, Subpart 000, The conveyor was in use and had not been tested. The equipment list denotes the
testing date as"to be tested." Mr. Ross could not find any evidence that this conveyor had been tested. 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.
The screens do not appear to be subject to Subpart 000 as being part of a wet process.
The facility was taking measures to control particulate. The facility is using a wet suppression system to control
emissions from the crushers, conveyors and screens. Fugitive dust issues are contained in 15A NCAC 2D .0540. To
control fugitive emissions, the facility has a water truck.
The primary crusher operates at a 6-7"jaw setting under normal operations, although the 650 maximum tons per hour
limit is based on a fully open (10"jaw) setting on the crusher,
Opacity readings from most emissions sources were below 10%.
The facility keeps records of hourly tonnage and wet suppression maintenance. The facility performs monthly inspection
and maintenance on the wet suppression system and records the information in a paper logbook. The inspection records
include inspector's initials,maintenance on pumps, nozzles, and hoses, and comments for cleaning and repairs. Records
were reviewed from January 1,2018 through April 30, 2019.
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The facility has two sources listed on their insignificant/exempt list. This includes a 65-ton cement silo(IES-Silo-I) with
bagfilters and a portable diesel-fired welder(IES-Weld-1). According to permit review R17 (Davis Murphy 8/8/2014),
the diesel-fired welder is not subject to 40 CFR 60 Subpart lilt. Neither source was in use during the inspection.
Permit Conditions/Applicable Regulations
Condition A.2 contains 15A NCAC 2D .0202 permit renewal and emissions inventory requirements. The facility was
issued a new permit on August 8, 2014. The permit expires on July 31, 2022, and the facility is required to submit a
renewal request and air pollution emission inventory report for the 2021 calendar year 90 days prior to the expiration of
the permit. Mr. Raines was made aware of the requirement. Compliance is expected.
Condition A.3 contains the 15A NCAC 2D .050I(c) requirements for equipment reporting. The permittee must maintain
a current equipment list and flow diagram on-site. The list must include the following:
• The total rated crushing capacity of all primary crushers.
• A description of equipment, including NSPS applicability.
• Width of belt conveyors.
• Dimensions and configurations of screens.
• Rated capacity of each crusher.
• Rated capacity of all equipment not exempt from permit requirements under 2Q .0102(c).
• A unique ID number.
• Date of equipment manufacture.
• Date any required performance testing was conducted and submitted to NC-DAQ.
The facility did not have an updated equipment list with the latest VE test dates, IDs, and manufacturing dates. Most
sources were represented on the most recent equipment list and flow diagram (01/2007), but a few sources have been
added or removed since 2007. As mentioned above in the discussion section, a new short-head crusher was installed in
2018. The conveyor list also needs to be updated as a couple conveyors have been removed from the process or removed
from the facility altogether. The dates for compliance testing on the new crusher need to be added as well as the testing
date for conveyor C-8,once it is tested.
The facility is allowed to install or relocate equipment(used for nonmetallic mineral processing equipment)as long as the
changes do not change the rated capacity of the primary crushing operation. If the facility adds equipment to their facility,
they must send a written notification to DAQ-WSRO which must include a revised equipment list and plant flow diagram.
The notification must be submitted 15 days before new equipment is installed or within 15 days of any relocation of
existing equipment. These change notifications have not been sent to DAO-WSRO as required. These changes should be
handled by the facility's technical contact,A. Scott Ross, from the Dublin,VA corporate office. The facility is in
violation of this condition.
Condition AA contains the 15A NCAC 2D .0510 requirements for controlling particulates from sand, gravel, and crushed
stone operations. The permittee shall control process emissions from crushers, conveyors, screens, and transfer points
such that opacity standards(contained in 15A NCAC 2D .0521 and 15A NCAC 2D .0524)are not exceeded. The facility
uses wet suppression systems to control particulate emissions. The wet suppression systems were in use during the
inspection and were observed to be operating effectively. Compliance is expected.
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. The facility must submit a permit application for any changes to the
crusher that are not considered "like-for-like." The crusher setting was confirmed to be set at 6 inches. Compliance is
expected.
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Condition A.6 15A NCAC 2D .0521 contains the visible emissions control requirement that restricts the opacity to be
under 20% when averaged over a six-minute period.The facility was operating at about 10%opacity for the crushing,
conveying, or screening operations during the inspection. Compliance is expected.
Condition A.7 15A NCAC 2D .0521 contains the visible emissions control requirement that restricts the opacity to be
under 40% when averaged over a six-minute period. The facility was operating at about 10%opacity for the crushing,
conveying, or screening operations during the inspection. Compliance is expected.
Condition A.8 contains the 15A NCAC 2D .0524 requirements for complying with the New Source Performance
Standards(NSPS) federal regulations for nonmetallic mineral processing equipment. The regulation is promulgated in 40
CFR 60, subpart 000. The regulation applies to the crushers,grinders, screeners, conveyors,and loading stations.
The facility must meet the following conditions:
• Notify the Regional Supervisor, in writing, of the startup of an affected facility.
• A 15% opacity limit is set for any crusher and 10%opacity for conveyor belts, screening operations and other
affected facilities constructed, modified or re-constructed after August 31, 1983,but before April 22, 2008.
• A 12% opacity limit is set for any crusher and 7% opacity for conveyor belts, screening operations and other
affected facilities constructed, modified or re-constructed on or after April 22, 2008.
• The facility is required to perform monthly inspections of the wet suppression systems and must record these
inspections within a logbook.
The facility presented the inspector with adequate records of the monthly inspections of the wet suppression systems.
The most recent monthly wet suppression inspection was performed on April 30, 2019. The inspection and maintenance
logbooks were reviewed back to January 2018.
The facility has failed to notify this office of any changes made to the process flow or equipment list. The last equipment
list, labeled "Equipment list for Vulcan Construction Materials-Shelton Quarry" is dated January 2007. Since that time,
the facility has made changes to the crusher and conveyor list. The facility and technical contacts are aware the list and
flow chart are outdated and need to be corrected.
The facility has not met the NSPS performance testing requirements. Conveyor C-8 was in use and had not been tested.
After some research, it was determined that the newly installed crusher was tested in August 2009. The most recent
Method 9 VE tests were performed in 2003. The facility is in violation of this condition.
Condition A.9 contains the 15A NCAC 2D .0535 which is a notification requirement for excess emissions during a
malfunction or breakdown that lasts for more than 4 hours. Mr. Raines reported that no incidents or malfunctions had
occurred. The office has not received any complaints concerning excess emissions at the facility. Compliance with the
condition is expected.
Condition A.10 contains the 15A NCAC 2D .0540 fugitive dust control requirement. 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 expected.
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 inspection. There have been no complaints regarding odors at the
facility. Compliance with the condition is expected.
Condition A.11 contains the permit reopening provision. The permit may be modified and reissued if some credible
emissions data is discovered that was not previously considered. The does not appear to be any addition emission
increases. Compliance is expected.
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NSPS/NESHAP
The facility must also meet the requirement of the 2D .0524, New Source Performance Standard (NSPS), as promulgated
in 40 CFR 60, Subpart 000, "Standards of Performance for Nonmetallic Mineral Processing Plants. The screens,
conveyors, and crushers are subject to the requirements and must comply with the notification, testing, reporting,
recordkeeping, and monitoring provisions contained in 2D .0524. The requirements of the regulation were addressed in
Condition A.B.
The facility does not have any emergency generators on location.
Permit Issues
There do not appear to be any permit issues at this time.
Facility Wide Emissions
As referenced in the latest permit renewal RI(Davis Murphy 08/08/2014)and based on emissions from calendar year
2013,the facility-wide potential and actual emissions are listed in the table below:
Pollutant CY 2013 Actual Emissions Tons/Year Potential Emissions Tons/Year
PM 4.2 45.678
PMio 1.8 17.287
PM2.5 0.7 3.7
Arsenic 0 4.643e-07
Beryllium 0 5.322e-08
Total Chromium 0 3.175e-06
Lead 0 1.193e-06
Man anese 0 1.281e-05
Nickel 0 4.577e-06
Stack Testing
The facility is responsible for scheduling, submitting the appropriate protocol, and conducting testing on conveyor C-8 as
soon as possible. The facility and technical contacts were made aware that this conveyor was not in compliance until it
has been tested. Mr. A. Scott Ross,technical contact, wrote in an email (05/21/2019)that he intended to conduct the
required VE test in June 2019.
Compliance History
The facility has not had any Notices of Deficiency or Violations within the past five years.
Conclusion
Based on the visual observations and review of records during the inspection and subsequent review, Southside Materials,
LLC-Shelton Quarry was found to be in violation with its Air Quality Permit, including state and federal air quality rules.
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