AQ_F_0400005_20190510_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Adams an Old Castle Company-Lilesville
NC Facility ID 0400005
Inspection Report County/FIPS:Anson/007
Date: 05/22/2019
Facility Data Permit Data
Adams an Old Castle Company-Lilesville Permit 01759/R22
351 Hailey's Ferry Road Issued 3/8/2017
Lilesville,NC 28091 Expires 2/28/2025
Lat: 34d 57.5360m Long: 79d 57.4490m Class/Status Synthetic Minor
SIC: 3272/Concrete Products,Nee Permit Status Active
NAICS: 32739/Other Concrete Product Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Kevin Tucker Colin Clampett Doug Fouts
Plant Manager President EH&S Manager
[phone] [phone] [phone]
7ni
ompliance Data
Comments: '
Date 05/10/2019
Name Mike Thomas
Inspector's ig ture: tatus Operating
�� e Code Compliance-inspection
e FCEDate of Signature: pection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2015 3.07 --- 0.7900 0.0400 0.6600 0.9800 28.30
2010 0.4400 0.0100 0.8800 0.0500 0.7400 0.2300 31.49
* Highest HAP Emitted(in pounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
04/21/2017 NOV/NRE 2D .0521 Control of Visible Emissions 05/05/2017
Performed Stack Tests since last FCE: None
Date Test Results Test Method(s) Source(s)Tested

1) Directions
From FRO, take Hwy 401 South to Wagram. Turn right onto Old Wire Road(Hwy 144)and go- 11 '/2
miles to Laurel Hill.Turn right onto US 74 West and continue for—25 miles until you enter Anson County,
just after crossing the Pee Dee River. Go—5 more miles to Hailey's Ferry Road(crossroads SR 1801),
where there is a large antique cart in a yard on the right and a sign for Welika Fish Camp on the left. Turn
left,go almost .2 mile, and then just before the railroad tracks,take a left onto facility's dirt drive. Main
office is on the right.
2) Safety Considerations
Standard DAQ safety equipment, including vest. Watch for forklifts and truck traffic throughout the
whole facility during inspection. Stairs and ladders are slippery because of cement dust
3) Facility and Process Description
Adams is a mineral mixing and packaging facility that primarily manufactures bagged concrete. It also
produces play sand,all-purpose sand, and mortar. The processing plant is on contiguous property with the W.
R. Bonsal mine. Raw materials are delivered on site, processed and dried through the sand and gravel dryer
and stored in designated silos. They are then blended and packaged/bagged according to the specified
concrete mix and customer. The company has 20 employees(including drivers) and operates 6AM—2:30PM
Mon-Fri,40 hrs/wk, 52 wks/yr.
4) Permitted Emission Sources
�. 3ssion n t4 '1�
es�ri st$ 1 eft i
FDrying Operation,consisting of:
Natural gas No.2 fuel oil-fired
(15 mmBtu max heat input)sand Bagfilter
ES30 and gravel dryer(50 tons per hour BH1A (3,825 square feet of filter area)',
maximum capacity)
Operating with 0%VE
Production Line 1,consisting of:
_ _ _ -
SF22 Portland cement silo,Line 1 BH22 Bagfilter
Operating with 0% VE (156 square feet of filter area)
SF23 Recycled cemenfsilo,Line 1 BH23 Bagfilter
Operating with 0%VE (156 square feet of filter area)
Fly ash silo,Line 1 BH24 Bagfilter
SF24
Operating with 0% VE �� 1(156 square feet of filter area)
SF25 No-mix cement silo, Line 1 BH25 Bagfilter
Operating with 0% VE — (156 square feet of filter area)
Rock and sand bucket conveyor
ES03 operation including a rock silo and BHIA Bagfilter
a sand silo (3,825 square feet of filter area)
Operating with 0% VE
Cement handling operation
ES01 (bagging,weighing,mixing),Line BHO1 Bagfilter
1 (3,840 square feet of filter area)
Operating with 0%VE

(Production Line 2,consisting of:
40 ton capacity Portland cement Bagfilter
SF40 silo Line 2 BH40 (156 square feet of filter area)
— C Operating with 0% VE
80-ton capacy Portland cement Bagfilter
SF 80 silo,Line 2 B V 80 [(_i
64 square feet of filter area)
Not installed ( -. _
145-ton capacity Portland cement Bagfilter
SF 145 silo,Line 2 B V 145 (264 square feet of filter area)
Not installed
------------------------------ ------ ----
SF41 Rock silo, Line 2 BH41 Bagfilter
Operating with 0% VE - (156 square feet of filter area)
-----...- -__.-- u
SF42 Sand silo split, Line 2 BH42 Bagfilter
Operating with 0/a VE (156 square feet of filter area)
Fly ash silo Line 2 BH43 Bagfilter
SF43 Operating with ne VE ;�(156 square feet of filter area)
-_- ____—.__._
SF44 Type S cement silo, Line 2 BH44 Bagfilter
Operating with 0% VE (156 square feet of filter area)
Recycled cement silo,Line 2 BH52 Bagfilter
SF52 Operating with 0% VE (156 square feet of filter area)
ES18 Rock screen from sand,Line 2 BH13 Bagfilter
I
Not operating (1,200 square feet of filter area)'
Cement handling operation
ES02 (bagging,weighing,mixing),Line BH02 Bagfilter
2 (1,900 square feet of filter are)
Operating with 0% VE
5) Inspection Conference
On 10 May, 2019, I Mike Thomas, Evangelyn Lowery-Jacobs, and Abdul Kandir,all of FRO DAQ,
conducted a compliance evaluation inspection of the Adams Old Castle Company—Lilesville facility.
We met with Greg Yule, Corporate Operations Manager. Mr. Yule stated that the Facility Contact,
Chris Tucker, no longer worked at the facility. He went on to say that the company has not found a
replacement for him. We discussed the following:
a) Upon arrival at the facility we observed what appeared to be excessive emissions coming
from the plant. After further investigation the emissions were coming from an employee
cleaning material off of one of the buildings. We asked Mr. Yule what was happening. Mr.
Yule stated that an overfill indicator on the bin on that roof had failed resulting in the
accumulation of material on the roof. He went on to say that the bin had been repaired and
that the only way to clean the roof was to do it manually. The material was being swept into
a container at ground level. Dust from this cleanup was not leaving he property boundary and
the work was completed by the end of this inspection.
b) Verified the FACFINDR information: Mr.Yule asked that he would notify this office once a
replacement for Mr. Tucker was found,but to leave him listed as the contact for now.
c) We reviewed the facility's maintenance and inspection logbooks. Records appeared to be
complete and up to date.

d) Production:
RiF .vy Ildll phi w
dui �b Af 9^R �ri ��� $p i �, a Y ti' �i +�i � �� . irfr fl' r
>
2018 59,091,060 59,091,060 6,523,300
2017 52,416,000 3,4070,000 - 18,000,000
2016 52,416,000 3,4070,000 - 18,000,000
2015 25,138,000 - 8,176,000 7,442,000
2014 24,015,260 4,574,860 - 662,280
2013 19,429,672 - -
2012 -
2011 5,017,514
6) Inspection Tour
Mr. Yule led us on a tour of the facility which was operating. We observed the interior location where
the final product is bagged and loaded onto pallets for distribution. Mr. Yule informed us that the
facility was continuing to us the Hi-Vac system that was installed last year to manage dust and clean
up in the bagging area. The Hi-Vac unit does not vent outside of the building it is housed in. Mr. Yule
showed us the roof top bin that had the mechanical failure and also the large container being used to
catch the material being swept from the roof.
I asked Mr. Tucker what their procedure was for receiving dry material into the silos. He stated that drivers
are instructed to fill silos at 10 to 12 psi to avoid exceeding the rate of the bagfilters. Trailers have an over
pressure valve that is triggered if the fill pressure exceeds 15 psi.
7) Permit Stipulations
a) A.2 15A NCAC 2D .0202 & 2Q .0304-PERMIT RENEWAL AND EMISSION
INVENTORY REQUIREMENT-The facility shall submit a permit renewal request and a
completed air emissions inventory at least 90 days prior to permit expiration.
APPEARED IN COMPLIANCE— The facility submitted their emissions inventory on 18
January 2017 and the permit renewal on 23 January 2017, before the required deadline. The
facility's next deadline for submittal will be December 2024 for the 2023 calendar year.
b) A.3 15A NCAC 2D .0515 PARTICULATE CONTROL REQUIREMENT—Particulate
matter emissions from sources shall not exceed the allowable rates as defined in the permit.
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) AA 15A NCAC 2D .0516 SULFUR DIOXIDE CONTROL REQUIREMENT—SO2
emissions from the combustion sources shall not exceed 2.3 Ibs/mm BTU.
APPEARED IN COMPLIANCE—The AP-42 emissions factor for No. 2 fuel oil is 0.002 lbs/mmBtu;
natural gas is 0.001 Ibs/mmBtu. Facility is only burning natural gas.
d) A.5 15A NCAC 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENT—Visible
emissions from the emission sources shall not exceed 20% opacity.

APPEARED IN COMPLIANCE No VE observed from any sources during the inspection. As stated
above there appeared to be excessive emissions but this was related to equipment failure that was
promptly fixed.
e) A.6 15A NCAC 2D .0535 "NOTIFICATION REQUIREMENT"—The facility shall notify the
DAQ if there are excess emissions that last for more than four hours due to malfunction,
breakdown of equipment, or other abnormal conditions.
DEFFICIENCY NOTED—On 13 April 2017,Jeff Cole of FRO DAQ observed excessive visible
emissions from the facility while traveling to another nearby facility. Mr. Cole's observations resulted in
the facility receiving a Notice of Violation/Recommendation for Enforcement. Mr. Tucker failed to
report the excessive emissions prior to them being observed by Mr. Cole.
f) A.7 15A NCAC 2D .0540 FUGITIVE DUST CONTROL REQUIREMENT- "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.
APPEARED IN COMPLIANCE—I observed no excess fugitive dust emissions during our inspection,
with the exception mentioned above. Dust from the cleanup operation did not appear to be leaving the
facility's boundary. The roads are gravel/sand. Mr. Yule stated that he has not received any dust
complaints.
g) A.8 15A NCAC 2D .0611 BAGFILTER REQUIREMENTS—Particulate matter emissions
shall be controlled as described in the permitted equipment list,the permittee shall perform, at a
minimum, an annual internal inspection of each particulate collection system. The permittee shall
also perform periodic inspections and maintenance as recommended by the equipment
manufacturer. The results of all inspections maintenance activities shall be recorded in the
logbook and kept onsite.
APPEARED IN COMPLIANCE—Separate logbooks are kept for each bagfilter system. An outside
company, Filter Kleen Environmental Service conducts monthly internal inspections and provides any
maintenance or repairs that are needed at that time. The most recent internal inspection took place on 23
April 2019. Note: any of these monthly inspections satisfy this permit stipulation. All entries were up to
date and complete.
h) A.9 15A NCAC 2Q .0315 LIMITATION TO AVOID 15A NCAC 2Q.0501(Titte V)-
Pursuant to 15A NCAC 2Q .0315 "Synthetic Minor Facilities," facility-wide PMjo emissions
shall be less than 100 tons per consecutive 12-month period. Facility complies with this
limitation by properly operating and maintaining their bagfilters and record keeping in
accordance with 15A NCAC 2D .0611 BAGFILTER REQUIREMENTS.
APPEARED IN COMPLIANCE— Facility met the requirements by performing the required
inspections,maintenance, and record keeping as prescribed in 15A NCAC 2D .0611 BAGFILTER
REQUIREMENTS. See A.8g above.
8) Non-compliance History Since 2010
January 18,2012 -NOD Failure to renew Air Permit
April 21, 2017—NRE for excessive visible emissions.
9) 112R Status
This 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).

9) Compliance Statement and Recommendations
Adams an Old Castle Company—Lilesville appeared to be in compliance with the conditions in their
current air permit on 10 May 2019.
Pink Sheet: No comments.
/mst