AQ_F_1900094_20190807_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Raleigh Regional Office
AIR QUALITY Pugh Concrete Company
Inspection Report NC Facility ID: 1900094
Date: 08/15/2019 County/FIPS: Chatham/037
Facility Data Permit Data
Pugh Concrete Company Permit: 08487/R05
4335 Silk Hope Gum Springs Road Issued: 3/2/2018
Pittsboro,NC 27312 Expires: 2/28/2026
Lat: 35d 46.2698m Long: 79d 18.3328m Class/Status: Small
SIC: 3273/Ready-Mixed Concrete Permit Status: Active
NAICS: 32732/Ready-Mix Concrete Manufacturing Current Permit Application(s):None
Program Applicability
Contact Data SIP
Facility Contact Authorized Contact Technical Contact
Douglas Pugh Douglas Pugh Douglas Pugh
President President President
[phone] [phone] [phone]
Compliance Data
Comments: Facility appears to be ' ompliance operationally with the excepti
of record keeping requirements. otice of Deficiency will a issue Inspection Date: 08/07/2019
Inspector's Name: Jeff Bouchelle
Inspector's Signature: Operating Status: Operating
Compliance Code: Compliance-inspection
Jeffrey L. Bouchelle Action Code: FCE
On-Site Inspection Result: Deficiency
Date of Signature: August 15,2019
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2016 0.4800 --- --- --- --- 0.2300 0.1560
2012 0.2620 --- --- --- --- 0.1210 0.0662
*Highest HAP Emitted(in pounds)
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
(I) DIRECTIONS TO FACELITY: From the Raleigh Regional Office (RRO), take I-440 to US Highway 64 (West)
towards Pittsboro. Continue on US Highway 64(West)taking the bypass around Pittsboro. Take Exit 381 and follow

NC Highway 87 (North) for approximately two (2)miles. Turn left onto Silk Hope/Gum Springs Road and continue
approximately four(4) miles. Pugh Concrete Company will be on the left,just before the driveway. [Look for sign
that reads, "Hoof Patter Farm"]. The facility is located at the back of the property behind the dairy farm. The road
down to the plant looks like a driveway to the farmhouse residence.
(II) FACILITY DESCRIPTION: Pugh Concrete Company is a concrete batch plant that employs approximately
fifteen(15)employees and operating Monday through Friday, 7:00am to 5:OOpm.
(III) SAFETY EQUIPMENT NEEDED: Personal Protective Equipment(PPE)includes,but is not limited to: 1)
safety steel-toed/composite shoes; 2) safety hard hat; 3)safety eye glasses; 4)hearing protection; and 5) a
highly reflective safety vest when conducting an inspection at this facility.
(IV) INSPECTION SUMMARY: On August 7, 2019,I(Jeff Bouchelle)inspected Pugh Concrete Company,
Pittsboro, Chatham County. The plant was operating at the time of this inspection. Mr.Douglas Pugh
(Owner)was not on-site during this inspection. He was said to be on vacation. Ms. Stacy Pugh White,Vice
President, was also not on-site during this inspection. A Mr. Christian Young, and a Mr. Rodney Duncan,
mechanics for the facility were on-site working. Mr.Christian Young assisted me with my inspection(records
and walk-through). First,I looked at the logbook for the bagfilter system. Next, I observed one truck being
loaded-out. Records for the facility are a combination of paper and electronic form. Also,records are not the
easiest to try and sort through and find rather quickly at this facility. I sat down and discussed this with Ms.
Evelyn Kidd, [phone]; [phone] (electronic data entry person for the facility), again this year on
this inspection,trying to develop a simpler spreadsheet for the required record keeping. There were no records
that could be made available to me during my inspection for"recording daily and total monthly the cubic yards
of concrete produced". Therefore,a Notice of Deficiency(NOD)will be sent to Pugh Concrete Company, for
this deficiency as noted in Air Permit No.:08487RO5,A.8.b.i.,"Record-daily and total monthly the cubic yards
of concrete produced."
(V) PERMITTED EMISSION SOURCES:
Em si si no Emission Source F,Control Control System
Source ID Description I System ID Description
Truck Mix Concrete Batch Plant#1(50 cubic yard per hour capacity)
ES-1 cement silo(40 ton capacity) CD-1 bagfilter(170 square feet of filter
ES-2 cement silo(75 ton capacity) area)
Truck Mix Concrete Batch Plant#2(50 cubic yard per hour capacity)
ES-3 cement silo(75 ton capacity) CD-4 ,cartridge type bagfilter(1,020 square
Not Meet of filter area)
installed,
but
,permitted.
ES-5 weigh batcher(8 cubic yard capacity) CD-3 cartridge type bagfilter(180 square
Not feet of filter area)
installed,
but
permitted.
Cement Storage Silos
ES-6 cement storage silo(180 tons storage capacity) CD-5 cartridge type bagfilter(1,020 square

Emission Emission Source Control Control System
Source ID Description System ID Description
ES-7 cement storage silo(180 tons storage capacity) (feet of filter area)
Appears to be in compliance.
(VI) SPECIFIC PERMIT CONDITIONS:
A.1. Any air emission sources or control devices authorized to construct and operate above must be operated
and maintained in accordance with the provisions contained herein.The Permittee shall comply with
applicable Environmental Management Commission Regulations,including Title 15A North Carolina
Administrative Code(NCAC), Subchapter 2D .0202,2D .0515,2D .0521,2D .0535, 2D .0540, 2D .0611,2Q
.0317 and 2Q .0711.
A.2.EMISSION INVENTORY REQUIREMENT-At least 90 days prior to the expiration date of this permit,
the Permittee shall submit the air pollution emission inventory report in accordance with 15A NCAC 2D
0202,pursuant to N.C. General Statute 143 215.65.
Appears to be in compliance.
A.3.PARTICULATE CONTROL REQUIREMENT-As required by 15A NCAC 2D .0515 "Particulates
from Miscellaneous Industrial Processes,"particulate matter emissions shall not exceed allowable emission
rates.
Appears to be in compliance. Compliance is expected through the use of a well-maintained bagfilter, as
evaluated in the permitting process.
A.4.VISIBLE EMISSIONS CONTROL REQUIREMENT-As required by 15A NCAC 2D .0521 "Control of
Visible Emissions,"visible emissions from the emission sources,manufactured after July 1, 1971, shall not be
more than twenty percent(20%)opacity when averaged over a six-minute period, except that six-minute
periods averaging not more than 87 percent opacity may occur not more than once in any hour nor more than
four times in any 24-hour period.
Appears to be in compliance. There were no visible emissions associated with this facility.
A.5.NOTIFICATION REQUIREMENT -As required by 15A NCAC 2D .0535,the Permittee of a source of
excess emissions that last for more than four(4)hours and that results from a malfunction, a breakdown of
process or control equipment or any other abnormal conditions, shall:
a. Notify the Director or his designee of any such occurrence by 9:00 a.m.Eastern time of the Division's next
business day of becoming aware of the occurrence and describe:
i. the name and location of the facility,
ii. the nature and cause of the malfunction or breakdown,
iii. the time when the malfunction or breakdown is first observed,
iv. the expected duration, and
V. an estimated rate of emissions.
b. Notify the Director or his designee immediately when the corrective measures have been accomplished.

Appears to be in compliance. According to Mr. Young, Pugh Concrete Company has not had a breakdown
that led to excess emissions.
A.6.FUGITIVE DUST CONTROL REQUIREMENT-As required by 15A NCAC 2D .0540 "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. If
substantive complaints or excessive fugitive dust emissions from the facility are observed beyond the property
boundaries for six minutes in any one hour(using Reference Method 22 in 40 CFR,Appendix A),the owner or
operator may be required to submit a fugitive dust plan as described in 2D .0540(f).
"Fugitive dust emissions"means particulate matter from process operations that does not pass through a
process stack or vent and that is generated within plant property boundaries from activities such as: unloading
and loading areas,process areas stockpiles, stock pile working,plant parking lots, and plant roads(including
access roads and haul roads).
Appears to be in compliance.A water truck is used to wet down the roads.
A.7.BAGFILTER REQUIREMENTS -As required by 15A NCAC 2D .0611,particulate matter emissions
shall be controlled as described in the permitted equipment list.
a. Inspection and Maintenance Requirements-To comply with the provisions of this permit and ensure that
emissions do not exceed the regulatory limits,the Permittee shall perform an annual internal inspection of the
bagfilter system.In addition,the Permittee shall perform periodic inspections and maintenance as
recommended by the equipment manufacturer.
b. Requirements-The results of all inspections and any variance from manufacturer's Recordkeeping
recommendations or from those given in this permit(when applicable) shall be investigated with corrections
made and dates of actions recorded in a logbook.Records of all maintenance activities shall be recorded in the
logbook. The logbook(in written or electronic format)shall be kept on-site and made available to DAQ
personnel upon request.
Appears to be in compliance. Inspections of the baghouse are being recorded in the logbook.
A.8.LIMITATION TO AVOID 15A NCAC 2D .1100"CONTROL OF TOXIC AIR POLLUTANTS"-In accordance
with 15A NCAC 2Q.0317,to comply with this permit and avoid the applicability of 15A NCAC 2D.1100"Control of
Toxic Air Pollutants," as requested by the Permittee, air toxic emissions shall not exceed the TPERs listed in 15A
NCAC 2Q .0711.
a. Operations Restrietions-To ensure emissions do not exeeed the lirftitations above,
the following restrietions shall
apply:
i. Concrete production shall not exceed 43,446 cubic yards per year.
Appears to be in compliance. 29,144.25 cubic yards of concrete were produced in 2018.
ii. Flyash supplements may not be used in the concrete mix.
Appears to be in compliance. No flyash is added.
b. Recordkeeping Requirements-The Permittee shall keep each monthly record on file for a minimum of three years.
The following requirements for recordkeeping shall also apply:
i. Record daily and total monthly the cubic yards of concrete produced.
In compliance.
A Notice of Deficiency (NOD) is being sent to Pugh Concrete Company for an infraction of this permit
requirement.

c. Reporting Requirements - Within 30 days after each calendar year, regardless of the actual production, the
following shall be reported to the Regional Supervisor,DAQ
i. Total cubic yards of concrete produced during the past year.
Appears to be in compliance.
A.9. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT -The facility shall be operated and
maintained in such a manner that emissions of any permit-listed TAPs from the facility, including fugitive emissions,
will not exceed TPERs listed in 15A NCAC 2Q .0711.
Appears to be in compliance.
(VH) COMPLIANCE HISTORY: A Notice of Deficiency(NOD) was issued on January 8, 2018, for a late submittal of
emissions inventory and permit renewal application along with required form AA.
(VIM INSIGNIFICANT/EXEMPT ACTIVITIES: There are no insignificant/exempt activities for this facility.
(IX) 112(r)APPLICABILITY: Pugh Concrete Company is not subject to program 112(r)Risk Management.
(X) SOURCE TESTING: There are no stack tests in IBEAM or scheduled for the near future.
(XI) EMISSIONS INVENTORY: Emissions calculations based on throughput numbers from CY2012 of 13,259 cubic
yards, actual particle emissions increased by approximately 88.69%when compared to that of the CY2016 emissions
calculations based on throughput numbers of 25,018 cubic yards. Throughput from CY2012 to CY2016 has almost
doubled.
(XH) CONCLUSIONS/RECOMMENDATIONS: At the time of this inspection, Pugh Concrete Company appeared to
be in compliance operationally with the exception of record keeping requirements. It is recommended this facility be
inspected again during the next two (2)years. ---JLB

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