Document 1QEMLvbZK18jpvzJa75D5DDe5

MEMORANDUM SUBJECT: CLEAN AIR ACT INSPECTION REPORT Shelly Company, Columbus, Ohio FROM: Sasha Letuchy, Environmental Engineer AECAB (MI/WI) THRU: Sarah Marshall, Section Supervisor AECAB (MI/WI) TO: File BASIC INFORMATION Facility Name: Shelly Company Facility Location: 395 Frank Road, Columbus, Ohio Date of Inspection: 11/8/2023 EPA Inspector(s): 1. Sasha Letuchy, Environmental Engineer 2. David Sutlin, Environmental Engineer Other Attendees: 1. Bernie Boggs, Foreman 2. Adeel Rind, Operations Manager 3. April Bott, VP Environmental for Shelly Company (on the phone for closing conference) Contact Email Address: april.bott@shellyco.com, adeel.rind@shellyco.com Purpose of Inspection: Asphalt plant inspection triggered by offsite observations of fugitive emissions Facility Type: Asphalt plant Regulations Central to Inspection: Ohio State Implementation Plan Arrival Time: 4:00 pm Departure Time: 5:15 pm Inspection Type: Unannounced Inspection Announced Inspection Facility Name: Shelly Company Facility Location: 395 Frank Road, Columbus, Ohio Date of Inspection: November 8, 2023 OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet via email with this report Provided CBI warning to facility The following information was obtained verbally from Bernie Boggs, Adeel Rind, and April Bott unless otherwise noted. Process Description: The facility operates a hot mix asphalt (HMA) plant with a maximum production rate of 300 to 500 tons per hour. Aggregate is transported from cold aggregate bins via a conveyor to the double barrel drum mixer. Recycled asphalt or RAP is injected in the middle of the drum and liquid asphalt cement is injected towards the front of the drum. The process operates continuously, and the drum rotates to dry the aggregate and mix the materials. The mixture is discharged at the end of the drum and conveyed to HMA storage silos where it is loaded into transport trucks. Emissions from the end of the drum are routed to a baghouse. Staff Interview: Bernie Boggs explained that he monitors the baghouse stack daily for visible emissions and records that information daily, along with the pressure drop across the baghouse. The EPA daily report was viewed on a computer monitor and confirmed that Bernie performs the daily inspections. The facility conducts annual inspections of the baghouse and maintains records of any maintenance conducted on the baghouse. Pressure drop was 3.4" water column (W.C.) on the day of the inspection and according to Bernie Boggs never dips below 2" W.C. The baghouse does not alarm when pressure drop is out of range. The water truck is used approximately three to eight times a day, as needed, to control road dust. No watering is performed if the temperature is below freezing. TOUR INFORMATION EPA Tour of the Facility: No Data Collected and Observations: EPA arrived at the site around 3:40 pm, just before shutdown and watched the operations from the roadway. Prior to entry, road dust had been observed leaving the facility, crossing the water, and Page 2 of 5 Facility Name: Shelly Company Facility Location: 395 Frank Road, Columbus, Ohio Date of Inspection: November 8, 2023 entering Frank Rd. EPA followed the source of the road dust and saw that many emissions were being generated by truck traffic from the roads owned by Shelly Company and the roads owned by neighboring entities. Upon approaching Shelly Company, EPA noted additional emissions at the top of the HMA storage silos on the west side and the north side. Photos and/or Videos: were taken during the inspection. See Appendix A. Field Measurements: were not taken during this inspection. RECORDS REVIEW EPA reviewed the November 7, 2023 EPA daily report which stated that the pressure drop was 3.2" W.C. and showed that a daily inspection of the baghouse had been conducted. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Concerns: EPA identified visible emission from the roadways and at the top of the asphalt silos. DIGITAL SIGNATURES ALEXANDR ALEXANDRA LETUCHY Digitally signed by Report Author: _A__L_E_T__U_C__H_Y___13_:4_8:2_0_-0_6'_00_' ____________ Date: 2023.12.19 Section Supervisor: SARAH Digitally signed by SARAH MARSHALL _M_A__R_S__H_A_L__L__1_5:_24_:2_5 _-06_'0_0'______________ Date: 2023.12.19 Page 3 of 5 APPENDICES AND ATTACHMENTS 1. Digital Image Log Facility Name: Shelly Company Facility Location: 395 Frank Road, Columbus, Ohio Date of Inspection: November 8, 2023 Page 4 of 5 Facility Name: Shelly Company Facility Location: 395 Frank Road, Columbus, Ohio Date of Inspection: November 8, 2023 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: David Sutlin 2. Archival Record Location: Electronics Records Center Image Number 1 File Name PB080332.JPG Date and Time (incl. Time zone and DST) 11/8/23 3:51pm Latitude and Longitude NA Description of Image Emissions from parking lot near Frank Rd. 2 PB080333.JPG 11/8/23 3:51pm NA Haziness near facility 3 PB080334.JPG 11/8/23 3:51pm NA Haziness over facility 4 PB080335.MOV 11/8/23 3:52pm NA 5 MAH00033.MPH/THM 11/8/23 4:09pm NA 6 MAH00034.MPH/THM 11/8/23 4:11pm NA 7 MAH00035.MPH/THM 11/8/23 4:15pm NA Video of dust generated from trucks and haziness Video of HMA tanks Video of intermittent emissions at the top of the HMA tanks Video of emissions at the top of the HMA tanks Page 5 of 5