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HomeMy WebLinkAboutAQ_F_1300129_20191009_CMPL_CAV-Rpt NORTH CAROLINA DIVISION OF Mooresville Regional Office AIR QUALITY Southern Concrete Materials-Concord Plant NC Facility ID 1300.129 Inspection Report County/FIPS:Cabarrus/025 Date: 10/09/2019 Facility Data Permit Data Southern Concrete Materials-Concord Plant Permit n/a 2807 Armentrout Drive Issued n/a Concord,NC 28025 Expires n/a Lat: 35d 22.6710m Long: 80d 34.6030m 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 Tim Cannon Jeff Lamm Jeff Lam_m Operations Manager Vice Vice (704)394-2344 President/Environmental President/Environmental Affairs Affairs 828 253-6421 828 253-6421 Compliance Data Comments_ Inspection.Date 10/09/2019 Inspector''s Name Donna Cook Inspector's Signature: a Coo �j Operating Status Operating Compliance Code Compliance-inspection is Action Code FCE Date of Signature: w / On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PMIO *HAP 2011 0.4200 =-- 0.1200 0.0100 0.1000 0.1900 4.21 2006 1.33 --- 0.0100 --- --- 0.6100 0.3700 *I-Eghest HAP Emitted inpounds) Five Year Violation History:None Date Letter Type Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested Southern Concrete Materials—Concord Plant October 9,2019 Page 2 Type Action: _Full Compliance _Partial Compliance _Complaint X Other:Compliance Assurance Visit Evaluation Evaluation/Reinspection Investigation CAV Data Tracking: X Date submitted for initial review 10/13/2019 _113EAM WARNING/OB,NOD,NOV,NRE X IBEAM Document X IBEAM Inspection,list date inspected X IBEAM LAT/LONG,Facility Locked X IBEAM Inspection,list date draft is submitted X IBEAM LAT/LONG,Coordinates checked X IBEAM Inspection,pollutants/programs checked _IBEAM Complaint X IBEAM Planning,Next Inspection Date 10/01/2021 Directions: From Mooresville Regional Office to Concord,travel via Highway 3 South;turn right on Odell School Road;turn right at the stop light onto Poplar Tent Road due to the no left turn;make a U turn at the next stop light;turn right on Highway 601/29(referred to as Concord Parkway);turn left on Highway 601 Bypass (Warren C. Coleman Boulevard)toward Monroe for approximately 2 '/z miles;turn right onto Armentrout Drive; and 0.2 mile on the right is this facility. The street address is 2807 Armentrout Drive. Safety Equipment: This company requires that steel toe shoes,hard hat, safety glasses and safety vest be worn by the inspector at this facility. Safety Issues: Inspector should be cautious of vehicle traffic and the front end loader at this facility. Lat/Long Coordinates: The facility's coordinates on "Maps of DAQ Regulated Facilities" are not accessible on the DAQ web site. The'latitude and longitude coordinates of this facility are accurate and locked in IBEAM. Email Contacts: The emails for the facility,authorized and technical contacts were verified by Mr.Bob Beeker, area manager. No changes to the email addresses of these contacts are needed in IBEAM. Compliance Assurance Visit: 1. The purpose of this site visit was to conduct a routine compliance assurance visit (CAV). This facility is a truck mix concrete batch plant rated at 125 cubic yards per hour. This company operates this plant from 4 a.m. to 4:30 p.m.; 10 hours per day, 6 days per week, 52 weeks per year. The operational schedule of this facility is dependent upon weather conditions and customer orders. Ms. Emily Supple coinspected this facility with me. Mr. Bob Beeker, area manager, accompanied us during the CAV. 2. Facility Contact Information:. During the CAV, I verified the facility contact information in IBEAM with Mr. Beeker. No changes to the facility contact information are needed in IBEAM. 3. Compliance history file review: No problems have been noted in the last five years by DAQ prior to the CAV. The current compliance status is discussed in the following sections. Southern Concrete Materials—Concord Plant October 9,2019 Page 3 4. Source Observations: The truck mix concrete batch plant is comprised of the following air emission sources and associated control devices: • one bagfilter(1500 square feet of filter area) installed on one cement silo (1000 barrel or 188 tons as indicated by Mr. Beeker); one flyash silo (380 barrel or 56 tons as indicated by Mr. Beeker); cement/flyash weigh batcher (20 cubic yards as indicated by Mr. Beeker) and a truck loadout. These sources were in operation. The differential pressure gauge installed on the bagfilter at ground level read 5 inches of water. The only source of visible emissions occurred when cement and flyash were gravity dropped from the weigh batcher into the mixer truck. I observed visible emissions ranging from 5%to,15% opacity from the truck loadout process. No tanker truck unloading of cement or flyash into the respective silos was occurring. Mr. Beeker stated that this company receives 0 to 15 loads per month(25 tons per load)of cement and 0 to 5 loads per month(25 tons per load)of flyash. One portable auxiliary cement silo(45 tons) and its associated bagfilter (165 square feet of filter area; 18 bags) are used in emergency. situations as indicated by Mr. Barnhardt. The portable auxiliary cement silo and associated bagfilter were not in operation. A tanker truck pumps` cement into the portable auxiliary cement silo. Then the cement is pneumatically blown from the auxiliary cement silo into the cement silo(1000 barrel or 188 tons). From the stock piles,the aggregate and sand are conveyed to storage bins,weighed and then conveyed through a rubber chute(boot) into mixer trucks. I observed no visible emissions from the aggregate and sand transfer process. The liquid concrete admixtures(water reducers, accelerators,retarders,plasticizers, and air entraining) and water are fed into the mixer trucks along with cement,flyash, sand and aggregate to form the concrete product. The admixtures are stored in plastic tanks. No visible emissions observed or odors detected from the admixture process. The natural gas-fired water heater(manufacturer,Bradford White; year, 1998; 3.08 output rating) rated at 1.54 million Btu per hour maximum heat input and output rating 3.08 million Btu per hour is used to heat the mix water during cold weather at this plant. The natural gas-fired boiler was not in operation at the time of the visit. This company has one aboveground diesel tank(12,000 gallon capacity)that is used to fuel the front end loader and mixer trucks. The aboveground storage tank is exempt per 15A NCAC 2Q .0102(g)(4). This office has not received any fugitive dust emissions complaints regarding this facility. This company has paved and unpaved areas at this-facility. Mr.Beeker stated that a mixer truck could be used to wet the unpaved areas of this facility. During this visit,I observed no fugitive dust from this facility. I asked Mr. Beeker if any excess emissions had occurred at this facility since the last CAV on October 18,2017. Mr. Beeker stated that no excess emissions had occurred at this facility. Southern Concrete Materials—Concord Plant October 9,2019 Page 4 5. NSPS/NESHAP Review: The exempt natural gas-fired water heater rated at 1.54 million Btu per hour maximum heat input is not subject to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Industrial, Commercial,and Institutional Boilers Area Sources(40 CFR Part 63, Subpart JJJJJJ or 6J), since the'rule does not apply to a water heater that is gas-fired. The exempt natural gas-fired water heater is not subject to 40 CFR Part 60,New Source Performance Standards(NSPS), Subpart Dc-"Standards of Performance for Small Industrial- Commercial-Institutional Steam Generating Units." The applicability of NSPS Subpart Dc to a water heater is constructed after June 9, 1989 with a maximum heat input capacity greater than 10 million Btu per hour. The water heater is rated 1.54 million Btu per hour maximum heat input and was manufactured in 1998. This company has no emergency generators,peak shaving generators,fire pump engines or gasoline storage tanks at this facility. 6. Exemption Qualification: The truck mix concrete batch plant with controls emits PM10 and HAPs/TAPS emissions. The combustion of natural gas from the boiler emits PM10, S02,NOx,VOC, CO and HAPs/TAPs emissions. This facility can be exempt from air quality permitting if the facility-wide actual emissions of PM10, S02,NOx,VOC, CO,HAPs and TAPs, each are less than five tons per year and the total actual aggregate emissions of these pollutants are less than ten tons a year per the exemption rule, 15A NCAC 2Q .0102(d). This company,provided five years of concrete production.records during the permit exemption process.The highest concrete production occurred in 2015 calendar year. MRO DAQ permitting determined using the concrete batch plant emissions calculator spreadsheet that 0.41tons of actual PM10 emissions were emitted based on 42,107 cubic yards of concrete produced by this plant. The total HAPs/TAPs emissions from this concrete plant were 0.00027 tons. This company reported 2.34 million cubic feet of natural gas in the 2011 emissions inventory. MRO DAQ permitting determined that the amount of natural gas'used based on 42,107 cubic yards was estimated at 5 million cubic feet per year. The natural gas emissions calculator was used by MRO DAQ permitting to calculate the following emissions from the natural gas combustion of 5 million cubic feet per year were 0.019 PM10; 0.0015 tons S02; 0.25 tons NOx; 0.014 tons VOC; 0.21 tons CO; and 0.013 tons HAPs/TAPs. The total aggregate emissions from the truck mix concrete batch plant and natural gas-fired boiler were 0.91 tons per year(0.41 +0.50=0.91 tpy). The concrete batch plant emissions calculator spreadsheet indicated that the truck mix concrete batch plant with controls would emit 4.971)tons PM10 if this plant produced 515,890 cubic yards of concrete in a year. The total PM10 emissions from the concrete batch plant and natural gas-fired boiler would still not exceed 5 tons per year(4.971 +0.019=4.99 tpy). This office sent a letter dated July 13, 2016 exempting this facility from permitting since the actual PM10, S02,NOx,VOC,CO,HAPs and TAPs emissions, each are less than five tons and the total aggregate emissions are less than ten tons per year. • J Southern Concrete Materials—Concord Plant October 9, 2019 Page 5 During this visit,I reviewed the concrete production records. The records indicated that this facility produced the following concrete: 32,200.15 cubic yards in 2017;25,054.3 cubic yards in 2018;and 14,592.75 cubic yards from January 1 to July 31, 2019. This facility still qualifies for exemption. In addition,no changes or modifications have been made to the equipment since the last visit. 7. Compliance determination: Based on my observations, this facility appeared to be in compliance with the air quality rules (21) .0515-particulates from miscellaneous industrial processes; 2D .0521-visible emissions; 2D .0535-excess emissions; and 2D .0540-fugitive dust emissions). The CAV checklist is attached on page 6. DLC:Ihe c: MRO File https://ncconnect.sharepoint.com/sites/DAQ-MR0/Counties/CABARRUS[00129/[NSPECT 20191009_CAV.docx Southern Concrete Materials—Concord Plant October 9,2019 Page 6 Compliance Assurance Visit Checklist rev.11/03/16 Facility Name:Southern Concrete Materials-Concord Plant Physical Site Address: 2807 Armentrout Drive City: Concord Zip Code: 28025 County: Cabarrus Facility Contact:Tim Cannon Title: Operations Manager Phone No.: (704)394-2344 Mai I ing Address: 715 State Street,Charlotte,INC 28208 Facility Contact Email Address: tcannon@scmusa.com Is the facility contact the person that you met? If not,fill out the following: Contact Name: Bob Beeker Title: Area Manager Phone No.:_(704)621-2919 Mailing Address: 2807 Arme ntrout Drive,Concord,INC 28025 Email Address: bbeeker@scmusa.com Safety requirements:safety shoes(yes/no)-safety glasses(yes/no)-hearing protection(yes/no)-hardhat(yes/no)- safety vest(yes/no) other(please describe) Normal operating schedule(hr/d,d/wk,wk/yr): 10 hr/d,5 d/wk,52 wk/yr Opacity(%)-indicate any non-zero opacities observed: 5%to 15%opacity from truck loadout Odors-indicate if any objectionable odors were detected beyond the property boundary: None Fugitive dust-indicate whetherfugitive dust was observed leaving property boundary: None Since last inspection,have there been any changes in equipment or operation? None Throughput and/or fuel usage with units: 125 cubic yards per hour maximum capacity at truck loadout Control device(s)(list): Bagfilter(15W square feet offilter area)installed on cement silo(1000 barrels or la tons);flyash silo(380 barrels or 56 tons);cement and flyash weigh batcher(20tons per hour)and a truck loadout. Portable auxiliary cement silo•(45 tons)and its associated bagfilter(165 square feet of fitter area;18 bags). Properly operated and maintained? Yes For a permit exempt facility found to be improperly operating or maintain!ng plant equipment:.1)provide compliance assistance as a first option;2)initiate enforcement action in egregious/repeat cases;3)re-evaluate facility's emissions using a more representative control efficiency/emission factor;4)If re-evaluated actual emissions result in a classification/ registration change,follow enforcement guidelines for operation without a permit/registration;and 5)increase compliance visit frequency. Notes or calculation space: Permit Exemption: •Actual emissions from the previous year(s)(and projected actual)of PM10,SO2,NOx,VOCs,CO,HAPs,and TAPs are each<5 tpy and whose actual total aggregate of these emissions are<10 tpy •Can be subject to 40 CFR Part 63(MACT or GACT)and 40 CFR Part 60(NSPS) •Cannot be subject to Rule 2Q.0315(Synthetic Minor Facilities)or2Q.0500(Title V Procedures) Concrete Batch Plant: Actual annual production(cy/yr): Concrete production in cubic yards:14,592.75 from Jan.1 to July 31,2019,25,054.3 in 2018; 32,200.15 in 2017. Truck mix or Central mix plant?: Truck/Central Mix (circle one) Controls?Bagfilter/Cyclone/None Boilers: #1 #2 #3 #4 ID No. 1 Installed or last modified date 1998 Size(mmBTU heat input) 1.54 input 3.08 output Primary/backup fuel: Natural Gas Fuel used(annual) Potential<5 tons NSPS Subpart Dc subject?' No NSPS Subpart Dc boiler if>10 mmBtu/hr and<100 mmBtu/hr installed or modified afterJune 9,1989. Yes/No/NA Gas only Dc subject boilers:have they submitted initial notification(only requirement)? Yes/No/NA Gas/fuel oil Dc subject boilers:records kept of each fuel type and startup notification for each fuel? Yes/No/NA Fuel oil certification required for Dc subject boilers(0.5%max S content). Are copies kept? Yes/No/NA If fuel oil Dc subject boiler>30 mmBtu/hr,was opacity testing performed on schedule based on results?2 `If VE=O%then done annually,<=5%done semiannually,<=10%done quarterly,>10%done every45 days. Yes/No' GACT 6.1 Gas Curtailment option claimed? Yes/No/NA If no,has a one-time energy assessment been performed. Yes/No/NA If no,are tune-ups being done biennially(25 months since last tune-up)? Yes/No/NA If yes,are records kept for natural gas curtailment and testing less than 48 hours peryear.