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HomeMy WebLinkAboutNCG140350_COMPLETE FILE - HISTORICAL_20160920wo 1 0A � G4,""'L STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. IV U& l y b 3-6 D DOC TYPE, 1�- HISTORICAL FILE ❑ MONITORING REPORTS DOC DATE ❑ aDI(p ��a YYYYM M DD NC®ENR North Carolina Department of Environment and Natural Resources Pat McCrory Donald R. van der Vaart Governor Secretary September 20, 2016 JUSTIN HARTLEY THOMAS CONCRETE OF CAROLINA INC. PO Box 12544 RALEIGH, NC 27605 Subject: Multimedia Compliance Inspection Thomas Concrete -Wake Forest Wake County Mr. Hartley: Department of Environment and Natural Resources staff from the Raleigh Regional Office conducted a multimedia compliance inspection of Thomas Concrete on September 13,2016 for permits and programs administered by the following Divisions: Division of Air Quality Division of Energy, Division of Water. Division of Waste Mineral, and Land Resources Management Resources We appreciate your cooperation during the inspection and hope that you have enjoyed the benefit of our initiative to provide a single inspector capable of handling multiple areas of environmental compliance at your facility. The results of each applicable inspection and any associated response actions or necessary corrective measures are detailed in the inspection letters/reports attached to this transmittal sheet. If you have any questions regarding this multimedia inspection or the results of each program inspection, please contact the Raleigh Regional Office at (919) 791-4200 and ask to speak with the appropriate Division . staff. Thank you for your cooperation. Copies: DAQ RRO Files DEMLR RRO Files DWR RRO Files DWM RRO Files NCDENR Raleigh Regional Office - 1628 Mail Service Center, Raleigh, North Carolina 27699.1617 Location: 3800 Barrett Drive, Raleigh North Carolina 27609 Phone: 919.791 A200 \ Fax: (919) 788-7159 An Equal Opportunity \ Affirmative Action Employer- Made in part with recycled paper PAT MCCRORY Covemor DONALD R. VAN DER VAART secretary September 20, 2016 Mr. Justin Hartley Thomas Concrete of Carolina., Inc. PO Box IZ544 Raleigh, NC 27605 Subject: NPDES Stormwater Compliance Evaluation Inspection Certificate of Coverage No. NCG140350 Thomas Concrete -Wake Forest Wake County Dear Mr. Hartley: Staff from the Department of Environmental Quality (DEQ) conducted a storm water inspection on September 13, 2016, as part of a multimedia inspection of your facility. The assistance provided by Mr. Andrew Rodak with Duncklee & Dunham and Casey Wiggins with Thomas Concrete during the inspection was greatly appreciated. The inspection report is attached. Findings during the inspection were as follows: Certificate of Coverage (COC) No. NCG140130 under NPDES General Permit NCG140000 was issued to Thomas Concrete of Carolina., Inc. to discharge storm water runoff to the Neuse River Basin. 2. The facility has developed and implemented a storriiwater pollution prevention plan (SPPP). A review of the plan indicated that it included all components required by the general permit. 3. Semi-annual qualitative and analytical monitoring has been conducted at one storm water discharge outfall (SDO), as required by the General Permit. However, TSS and ph readings have consistently shown levels above the approved benchmark when a sample could be taken: The facility is actively sampling according to the tier two protocol, but according to the guidelines of the permit, should have initiated tier three protocol. This requires that the facility notify the DEMLR Regional Office Supervisor (John Holley) in writing within 30 days of the receipt of the fourth analytical results above the benchmark. Additional measures or practices which need to be implemented and a report outlining actions taken and follow up analytical results is also required. Raleigh Regional Office1628 Mail Service Center, Raleigh, North Carolina 27699-1628 Phone:.919-791-4200 / FAX: 919-571-4718 / Internet: http://portal.ncdenr.org/web/lr/ An Equal Opportunity \ Affirmative Action Employer — 50% Recycled \ 10% Post Consumer Paper Page 2 of 2 4. The SDO was observed and found accessible. An additional outlet point was identified that was not shown on,the plan and was not actively being sampled. This additional SDO will need to be added to the site map and sampling should begin immediately. The facility has the option to eliminate the runoff to that outlet point, if practical, and divert the runoff to the existing, sampling point (SDO) shown on the site map. If you have any questions regarding the attached report or any of the findings, please contact Thad -- .. .. Valentine at 919-791-4200 (or email: thad.valentine(c�ncdenr.g_ov).. , V" - I Compliance Inspection Report Permit: NCG140350 Effective: 07/01/16 Expiration: 06/30/17 Owner: Thomas Concrete of Carolina Inc SOC: Effective: Expiration: Facility: Thomas Concrete -Wake Forest Plant County: Wake 2621 Teletec Piz . Region: Raleigh - Wake Forest NC 27587 Contact Pelson: Accounts Payable Title: Phone: 919-562-1909 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(a): Related Permits: Certification: Phone: Inspection Date: 09/13/2016 Entry Time: 10:30AM Exit Time: 12:OOPM Primary Inspector: Thaddeus W Valentine Phone: Secondary Inspectore): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Ready Mix Concrete Stormwater/Wastewater Discharge COG Facility Statue: E] Compliant Not Compliant _ Question Areas: E Storm water (See attachment summary) Page: 1 permit. NCG140350 Owner • Facility: Thomas Concrete of Carolina Inc Inspection Date: 09/13/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: 1. Please address the issue with the outfall in the NE corner of the parking lot that is not shown on the site map or being sampled. Reply by September 30th outlining the method for resolving that issue. - - 2. Clean up the concrete deposited at the top of the hill and down into the stream at the NE corner of the parking lot— ... 3. Place the oil drums and the used batteries inside the shop or under a shelter. Cover the greasy used parts drum and cap off any drums that are missing plugs or otherwise open. 4. Add the required extra samples to the protocol for the maintenance shop (oil and grease) 5. Repair broken drain valves and secure all drain outlets for the secondary containment areas. - 6. Due to repeated high concentrations of TSS and ph, Tier 3 should be implemented and the Raleigh Regional Engineer. John Holley should receive in writing notification of such with a copy of the last analytical results. The permittee is required to implement additional methods to address the high TSS and ph results and submit a plan of action for that resolution by October 15th. - Page: 2 permit: NCG140350 Inspection Date: 09/13/2016 Analytical Monitoring Has the facility conducted its Analytical monitoring? Owner -Facility: Thomas Concrete of Carolina Inc Inspection Type : Compliance Evaluation Reason for Visit Routine # Has the facility conducted Its Analytical monitoring from Vehicle Maintenance areas? Comment: of oil per month so the sampling requirements for that condition should be implemented., Permit and Outfalls - Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ®0 ❑ ❑ # Were all ouflails observed during the Inspection? El ■ ❑ ❑ # If the facility has representative outfall status, Is it property documented by the Division? ' ❑ ❑ # Has the facility evaluated all Illicit (non stormwater) discharges? i El ❑ ❑ Comment: The one additional cutfall noted during our walk through should be addressed Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? M❑ ❑ ❑ Comment: Samoles recorded Stormwater Pollution Prevention Plan Does the site have a Stormwater Pollution Prevention Plan? ■ El El El # Does the Plan Include a General Location (USGS) map? - ® ❑ Q ❑ # Does the Plan Include a `Narrative Description of Practices"? e ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas?El ®Q El # Does the Plan Include a list of significant spills occurring during the past 3 years? M,El El El # Has the facility evaluated feasible alternatives to current practices? M El ❑ ❑ # Does the facility provide all necessary secondary containment? ®El ❑ ❑ # Does the Plan include a BMP summary? ®El ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ® ❑ 0 ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? . ❑ ❑ ❑ # Does the facility provide and document Employee Training? - 0 ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? a 0 ❑ ❑ # Is the Plan reviewed and updated annually? . ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ®1:1 ❑ Page: 3 Peank: NCG140350 - Owner -Facility: Thomas Concrete of Carolina Inc. Inspection Date: 09/13/2016 Inspection Type: Compliance Evalua ton Reason for Visit Routine Stormwater Pollution Prevention Plan - Yes No NA IN Has the stormwater Pollution Prevention Plan been implemented? - _ ® ❑ 1111 Comment: While walking the site an additional outfall was discovered on the NE side of the Parking lot that was not shown on the site map or being sampled It aPoe ared concrete was scraped -and Page: 4 r NORTH CAROLINA DIVISION OF AIR QUALITY Inspection Report Date: 09/16/2016 Facility Data Kaieigh Regional Office Thomas Concrete of Carolina - Wake Forest NC Facility ID 9200650 County/FIPS: Wake/183 Permit Data u Thomas Concrete of Carolina - Wake Forest 2621 Teletec Plaza Wake Forest, NC . 27587 Lat 35d 55.2590m . Long: 78d 32.9710m SIC: 3273 / Ready -Mixed Concrete . NAICS: 32732 / Ready -Mix Concrete Manufacturing Facility Contact Authorized Contact Technical Contact Casey Wiggins Tim Coughlin Justin Hartley Plant Manager Senior Vice President Area Manager (919)562-1909 (919) 832-0451 1 (919)832-0451 Comments: Compliance Assurance Visit —/In Compliance Inspector's Signature: l U�1^- Date of Signature: I Total Actual emissinnu in TnNSlVFAR- Permit n/a Issued n/a Expires n/a Classification n/a Permit Status Permit Exempt Current Permit Application(s) None Program Applicability SIP Data Inspection Date 09/13/2016 Inspector's Name Thaddeus Valentine Operating Status Operating Compliance Code Compliance - inspection Action Code FCE On -Site Inspection Result Compliance TSP S02 NOX VOC CO PM10 *HAP 2013 0.2543 --- --- --- 0.1211 0.0109 2008 4.95 --- --- --- --- 2.33 0.0692 None None (1) DIRECTIONS TO SITE: From the RRO, take I440 Inner Beltline to Capital Boulevard North. Go through the intersection at Burlington Mill Road. Immediately after this intersection, get in the left lane and turn around at the two-way connector. Teletec Plaza will be the next road on the right. The facility is located at the end of Teletec Road. (In FACILITY DESCRIPTION: The facility is a concrete batch plant. Standard safety gear is to be worn on facility visits. (III) INSPECTION SUMMARY: On September 13, 2016, I (Thad Valentine) met with Mr. Casey Wiggins, Plant Manager & Andrew Rodak, their Environmental Consultant, to conduct a compliance assurance visit at the Thomas Concrete Wake Forest Plant. Thomas Concrete submitted a request to DAQ on July 14, 2016, to have their air permit for the Wake Forest plant rescinded since the facility's overall emissions are below the new permit exemption thresholds in 15A NCAC 2Q .0102. The request for permit rescission was approved, and the facility's air permit was inactivated on September 8, 2016. According to the rescission request review document, this concrete batch plant remains eligible for permit exemption as long as total plant _ production does not exceed 500,000 cubic yards of concrete per year. During my September 13, 2016 site visit, I checked the plant's monthly and annual production rates, and they were well below the permit exemption limit. For calendar year 2015, the Wake Forest plant produced a total of 24,648 cubic yards of concrete and the YTD production total for 2016 is 19,540 tons. I also visually inspected the condition of the plant's bagfilter systems and the associated ductwork, and all plant equipment appeared to be well maintained and in good working order. No visible emissions were observed from any of the plant's emission sources. No fugitive dust or odorous emissions were observed beyond the facility's property boundary. I reviewed the plant's inspection and maintenance records, and they appeared to be complete and up to date. The last bagfilter inspections at the plant were performed July 19, 2016 with'no problems found. Filter Kleen regularly inspects the facility's baghouses. Overall, the facility appeared to be operating well from an air quality standpoint A copy of the DAQ Compliance Assurance Checklist is attached to this report. (IV) COMPLIANCE HISTORY: This facility has not been issued any NODs or NOVs within the last five years. (V) CONCLUSIONS/RECOMMENDATIONS: At the time of the compliance assurance visit, the facility appeared to be in compliance with all applicable au quality regulations. The facility's overall emissions were verified to be below the permit exemption thresholds. It is recommended that the facility be revisited in two years. Attachment Coin Iiance Assurance'Visit Checklist rev.8/05/16 Facilik; ame: ' Physical Site Address: City: C,' Zip Code ::x7 County: :W 64 G Facility Contact: Title: Phone.No.i';cj 5-& — Mailing'Address Q /3dr nJ_S CP ffu — LIZ ` �7 .. tj Facility Contact Email Address: Is the facility contact the person that you met?. if not, fill out the. following: Contact Name: ;u' L Title: Phone No.:,.:... Mailing Address: `Sr' Email Address: C'O?w_ Safety requirements safety shoes ye no) -safety glassesno) hearing protection (yes, ,hardhat es no) other.(please descri e): Normal operating schedule (hr/d, d/wk, wk/yr): Opacity (%) - indicate any nonzero opacities observed: Odors indicate if any objectionable odors were detected beyond the property boundary: Mph_ Fugitive dust - indicate whether fugitive dust was observed leaving property boundary: AJQ tiff Since'last inspection, have there been any changes in equipment or operation? Throughput and/or fuel usage with units: Control device(s) (list): Properly operated and maintained? 14 k5- For permit exempt facility ) found to be iro P P m erlY p g o eratin rmamtaining plant equipment 1) provide compliance assistance as a first o tion 2 initiate enforcement action m e regious repeat cases; 3) re evaluate'fa' ility'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, S02, 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) or 2Q.0500.(Title V Procedures) Registration: • Actual aggregate emissions >= 5 tpy and < 25 tpy: PM10, CO, NOx, S02, VOCs, HAPs, and TAPS. • Cannot meet permit exemption under 2Q.0102(d) • Cannot be subject to Rule 2Q .0315 (Synthetic Minor Facilities) or 2Q.0500 (Title V Procedures) • Cannot be subject to 40 CFR Part 63 (MACT) {Can be subject to 40 CFR Part 63 (GACT)) • Cannot emit volatile organic compounds or nitrogen oxides if the facility is located in a nonattainment area • Cannot be subject to 40 CFR Part 60 (NSPS) except for sources which are exempt under 2Q .0102 (g) or (h) 6 Boilers: AUAL ID No. #1 #2 43 #4 Installed or last modified date Size (mmBTU heat input): Primary/backup fuel:.. Fuel used (annual)' NSPS Subpart Dc subject?. 'NSPS Subpart Dc boiler if >10 mmBtu/hr and <1UU mmbtu/nr instanea or moamea arcer June 7, 1707. 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 boilers (0.5% max 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?` Yes / No / NA `If VE=O%then done annually, <=5% done semiannually, <=10%done quarterly, >10%done every 45 days. GACT 6J Gas Curtailment option claimed? Yes / No . 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 per year. Yes / No / NA Generators: ID No #1.,.. #2.. .._..... #3..::.. ,__ #4 Engine type: emergency, peak shaving, or non -emergency /process related.' Size (hp and_kW) Fuel type Manufacture date Constructed (ordered).date NSPS 41, 4J, or NESHAP 4Z subject? NSPS 41, 4J, or NESHAP'4ZYeq met?, If spark engine gas -only units),indicate ' 4SRB; 45LB, 2SRB, or 25L8 Control Device if non -emergency.;;= Fuel oil cert (<15 ppm S) copies kept? Hour meterreadm ' g; 41"subject if Cl engine constructed (ordered) after 7/11/05 and manufactured after 4/1/06 . 4J subject if SI engine constructed (ordered) after 6/12/06 and manufactured after 4/1/06 4Z: existing constructed before 6/12/06 or new constructed on orafter 6/12/66 (compliance shown with 41 or 4J compliance). Emerge ncy:'<100 hr/yrvon-emergency use. allowed: No notifications required Maintenance req: change oil/filter inspect hoses/belts every 500 hrs/annually & air cleaner every 1000 hrs/ann; gas units inspect spark plugs every 1006 hrs/ann. Non=emergency': performance test, operating limitations; notifications; semiannual compliance report's, and maintenance: Is unit used for demand response? if so, cannot be considered emergency use after 5/1/16. Notes or calculation space. tonne ete Batch Plant77 Actual annual production (cy/yr): f CI S Truck mix or, Central mix; plant?: Trucl' Central MR) (circle one) Controls Baghous / Cyclone / None Quarries: Annual production (tpy): Crushers How many? Wet suppression? Primary Y / N Secondary 777TN Tertiary Y / N Screens: Y / N Conveyer transfer pts Y / N Is facility NSPS Subpart 000 subject (manufactured after 8/31/83). Yes / No / NA If subject, must have site map; updated equipment list with throughputs, and initial PM/opacity testing. Yes / No / NA sa a an Type (Drum or Batch): Annual production (tpy): Fuel type. Fabric filter (y or n) Date constructed or modified: Dryer rating (mm8tu/hr):.. If afterjune ll; 1973 then subject to NSPS Subpart I and RAP Crushing onsite? Methods San d 9 testing required. If yes, lump buster or crusher . If applicable, test date: AC heater rating (m . u/hr) FeedMills: Indicate throughput (in tpy) for each:, Process:. Process: t Unloading: Bin Loading: General (dump end) Load out (Shipping): Railcar hopper bottom dump pit Truck Truck hopper bottom dump pit Rail Cleaning: Hammermill: Drying: Cyclone Column,. Baghouse Rack Pellet Coolers: Internal operations: Cyclone - std eff. (belts, grain cleaner, head house, Cyclone - high eff. closed -loop system -w/o grain clean) NESHAP Subpart 7D subject if operate a prepared feeds manufacturing facility that uses a material containing Cr or Mn. If subject, how is compliance demonstrated? Woodworking; %eachmusttotal 100 Wood waste (tpy): Planing or Sawing /chipping Throughput (board ft/yr): Rough sawing Wet / dry wood? Fine sawing Bagfilter or cyclone? Milling (&hog) Molding Sanding Wood Kiln: Throughput (board ft/yr): Hardwood: Softwood: For softwood, circle one kiln type: steam heated, direct -fired suspension, or direct -fired kiln gasifier.