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.