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HomeMy WebLinkAboutAQ_F_0500070_20190530_CMPL_CAV-Rpt (6) NORTH CAROLINA DIVISION OF Winston-Salem Regional Office AIR QUALITY Chandler Concrete Co., Inc. -Crumpler Plant 504 NC Facility ID 0500070 Inspection Report County/FIPS: Ashe/009 Date: 05/30/2019 Facility Data Permit Data Chandler Concrete Co., Inc. -Crumpler Plant 504 Permit n/a 1992 NC Highway 16 North Issued n/a Crumpler,NC 28617 Expires n/a Lat: 36d 26.8920m Long: 8 1 d 24.7920m Class/Status Permit Exempt SIC: 3273/Ready-Mixed Concrete Permit Status Inactive NAICS: 32732/Ready-Mix Concrete Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Sam Thompson Kenneth Waegerle Kenneth Waegerle Area Manager Corporate EHS Manager Corporate EHS Manager (828)264-8694 336 226-1181 336 226-1181 Compliance Data Comments: Inspection Date 05/30/2019 Inspector's Name Chris Bryant Inspector's Signature: Operating Status Operating Compliance Code Compliance- inspection Action Code FCE Date of Signature: 6111 y MTH On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PMIO * HAP 2012 0.1700 --- --- --- 0.0800 0.0481 2008 0.2000 --- --- 0.0900 0.0500 * Highest HAP Emitted inpounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 07/02/2014 NOV Permit Permit Condition 07/15/2014 Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested 1 Emission Sources Emission Emission Source Control — Control System Source ID Description System ID Description lone truck mix concrete batch plant(84 cubic yards per hour maximum capacity)consisting of: ES-I Cement storage silo CD-I Cartridge filter(960 square feet of filter area) F ES-2—[_ Flyash storage silo r CD-2 Bagfilter(225 square feet of filter area) __.._ __.._....,.... .. ._____ ' - _ ...._--..._ -.._ ._..___.. __...___.__._..._.... .__...._..._ ES-3 Cement/flyash weigh hopper ( CD-3 � Cartridge filter(110 square feet of filter area) ES-4� — Truck loadout operation CD-4 Bagfilter(896 square feet of filter area) One hot water heater i I 1-ES-5 propane-fired N/A N/A (0.2 million Btu/hr heat input capacity) 1-ES-6 Concrete admixture tanks N/A N/A (300 to 500 gallons' capacity, each) Introduction On May 30,2019, Mr. Chris Bryant, Environmental Specialist of DAQ WSRO, contacted Mr. Rex Burgess, Plant Manager, and Andy Goodnight, Production Manager,of Chandler Concrete Co.,Inc. -Crumpler Plant#504 for an announced targeted compliance assurance visit. The facility was previously visited on June 28,2017 by Paul Williams and Hunter Johnson of DAQ WSRO and was found to be operating in compliance will all applicable Air Quality standards and regulations at that time. The facility applied, on July 28,2016, and was granted a permit rescission on August 1,2016. This facility is a truck-mix concrete batch plant with a maximum rated capacity of 84 cubic yards per hour. The facility contact, Mr. Ken Waegerle, is the Corporate EHS Manager and was not on-site for the compliance visit. The facility operates Monday through Friday, 7:00am to 3:30pm, 36-40 weeks/year. Safety Equipment Safety shoes, eye protection, and hearing protection are required within manufacturing areas. Applicable Regulations Applicable regulations for this facility include Title 15A NCAC, Subchapter 2D .0503,2D .0515, 2D .0521,2D .0535, 2D .0540, 2D .0611 and 2D .1806. This 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 in the rule. The facility is also subject to the General Duty requirements contained in the General Duty Clause. Discussion Mr. Chris Bryant met with Mr. Burgess and Mr. Goodnight on the morning of May 30, 2019 at Chandler Concrete Co., Inc. - Crumpler Plant#504. The company has several emission sources consisting of a cement silo(ES-1), flyash silo (ES-2), weigh hopper(ES-3), truck loadout(ES-4), a propane water heater(1-ES-5),and admixture tanks (I-ES-6). The corresponding control devices,cartridge filter(CD-1), bagfilter(CD-2), cartridge filter(CD-3), and bagfilter(CD-4) were observed. The control systems and ductwork appeared to be in good condition. The facility was dispensing concrete during the visit. The company receives cement deliveries once a week and fly-ash approximately once a month. In 2018, the facility processed 10,920.5 yards of concrete and 2,986 tons of cement. The facility receives rock from Mountain City, TN and natural sand from Candor,NC. The control device maintenance records were reviewed and appeared to be complete. Inspections are performed on all four control devices every few weeks. The most recent internal inspections were indicated to have been performed on May 3,2019,April 18,March 28,March 8, February 25, February 2, and January 18, 2019. This facility operates a 0.2 million Btu/hr propane-fired hot water heater(I-ES-5),which used to heat process water during orders that are produced in cold weather periods. The facility also utilizes and maintains several admixture tanks (I-ES-6). 2 Regulations Applicable to this Facility 15A NCAC 2D .0503 is the particulate control requirement. This regulation sets emission limits for the propane-fired water heater(I-ES-5). The facility solely combusts propane and thus should likely be compliant with this requirement. 15A NCAC 2D .0515 contains the particulate control requirement. This condition sets the maximum allowable particulate emissions using the following equations: E=4.10 * (P)1.61 for P<= 30 tons/hr, or E= 55 * (P)°"-40 for P>30 tons/hr The regulation is applicable to all permitted equipment. The bagfilters and controls systems appeared to be properly installed and adequately maintained. Compliance is expected. 15A NCAC 2D .0516 contains the"Sulfur Dioxide Emissions from Combustion Sources"requirement. This requires that the emissions rate for each source be less than 2.3 Ill SG2/MMBtu. This requirement applies to the combustion sources. ,file actual emissions, based on the combustion of propane, are significantly below the allowable limit. Compliance is expected. 15A NCAC 2D .0521 contains the visible emissions control regulation. This facility is limited to 20%opacity for sources manufactured after July 1, 1971 and a 40%opacity for sources manufactured as of July 1, 1971, when averaged over a six-minute period. The visible emissions observed during this visit appeared to be near 0%opacity. There was no evidence to indicate that the facility had or was having any visible emission violations. Compliance is expected. 15A NCAC 2D. 0535 contains the excess emissions reporting requirement. The facility must notify the DAQ of any malfunctions associated with a source causing an excess of emissions lasting more than four hours. The facility is equipped with bin indicator light that alert the company personnel of malfunctions. Mr. Burgess stated that there have been no such incidents since the prior compliance visit. There was no indication of any malfunction to the control devices or process equipment. Compliance is expected. 15A NCAC 2D .0540 contains the fugitive dust control regulation. No fugitive dust was observed traveling beyond the property boundaries during this visit. The facility is located in a commercial area, away from other residential dwellings. Compliance with this requirement is indicated. 15A NCAC 2D .0611 contains the monitoring emissions from other sources requirement. The facility presented records of bagfilter maintenance to Mr. Bryant during the visit. The facility conducts bagfilter inspections and maintenance at least monthly. The last entry for the facility's bagfilter logbook showed that an inspection had been performed on May 3, 2019. Compliance is expected. 15A NCAC 2D .1806 contains the control and prohibition of odorous emissions requirement. No objectionable odors were detected during the approach to the facility or at the property boundaries. The facility does not have any previous odor complaints in (BEAM. Compliance with this requirement is indicated. NSPS/NESHAP This facility does not appear to be subject to any NSPS or NESHAP rules at this time. Facility Wide Emissions The following emission information is from calendar year 2015, listed in rescission review(Leo Governale, 8/l/16), and repeated below: 3 Pollutant CY 2008 Actual Emissions CY 2012 Actual Emissions (ton s/yr) (tons/yr) PM 0.20 ���-0.17��- PMio S02 I CO Not Repotted* NOx I i We 0.00 0.00 Total HAPs 0.0000545 0.000055 Highest HAP(Manganese) 0.000025 0.000024 *SO2,CO and NOx emissions are generated from the Propane-fired Hot Water Heater(I-ES-5);however,they have not been reported. It is reasonable to consider that these emissions are insignificant,due to the small size of the unit and its limited(seasonal)use,and assume that the exemption threshold limits would easily not be exceeded. Facility Considerations/Issues There are no significant permitting or emission source issues to address at this time. Stack Testing No stack testing has ever been conducted at this facility. 5 Year Compliance History The facility was issued a Notice of Violation (NOV)on July 2, 2014 for failing to perform the required annual internal inspection of cartridge filter CD-3. This NOV was resolved, July 15, 2014, when the facility response was received stating that filter CD-3 had been inspected, cleaned and installed. Conclusion Based on visual observation and review of records, Chandler Concrete Co., Inc.-Crumpler Plant 504 appears to be operating in compliance with all applicable Air Quality standards and regulations at the time of this compliance assurance visit. 4