Document K6yn9xjLBppnwOezyMYxngJz0
United States Environmental Protection Agency Region 7
Enforcement and Compliance Assurance Division Air Branch Inspection Report
Unannounced Full Compliance Evaluation Mississippi Lime Company 16147 US Highway 61 Ste. Genevieve, MO 63670 FRS# 110030914367
Inspection Date(s): March 7, 2023
Luke Rodriguez, Inspector, ECAD, Air Branch
Authorized for Release by:
Tracey Casburn, Air Branch Chief, ECAD
11201 Renner Boulevard Lenexa, Kansas 66219
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CONTENTS INSPECTION OVERVIEW........................................................................................................... 3
INSPECTION OBJECTIVE....................................................................................................... 3 FACILITY CONTACT INFORMATION ................................................................................. 3 FACILITY OVERVIEW ............................................................................................................ 4 FACILITY OPERATIONS SUMMARY................................................................................... 4 FIELD ACTIVITIES SUMMARY............................................................................................. 4 INVESTIGATION OBSERVATIONS AND POTENTIAL FINDINGS...................................... 5 TABLES Table 1. APPLICABLE REGULATIONS AND STANDARDS................................................................. 3 Table 2. PROJECT TEAM MEMBERS....................................................................................................... 3 Table 3. FACILITY CONTACT INFORMATION...................................................................................... 3 Table 4. SUMMARY OF MISSISSIPPI LIME COMPANY KILNS PM EMISSION STANDARDS..... 10 Table 5. EVALUATION OF OM&M PLAN REQUIREMENTS ............................................................. 12 APPENDICES A Receipt for Documents (1 page) B Field Photographs (12 pages) C Selected Performance Tests (336 pages) D Example Engine Maintenance (3 pages) E Selected COMs Audits and Calibrations (70 pages) F OM&M Plan and SSM Plan (59 pages) G Peerless Kilns 1 and 2 Maintenance Work Order (26 pages) H Excel Spreadsheet of Preventative Work Orders (N/A) I Visible Emission Checks (12 pages)
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INSPECTION OVERVIEW
INSPECTION OBJECTIVE
The objective of the full compliance evaluation (FCE) inspection was to determine compliance of the facility with the Clean Air Act (CAA), specifically those requirements located in the code of federal regulations at 40 CFR Parts 60 and 63 in Table 1. The inspection was part of the U.S. Environmental Protection Agency's (EPA) Creating Cleaner Air for Communities National Enforcement Compliance Initiative.
Code of Federal Regulation 40 CFR Part
60
40 CFR Part 63
Table 1. APPLICABLE REGULATIONS AND STANDARDS
Standard Name
Subpart A, General Provisions Subpart HH, Standards of Performance for Lime Manufacturing Plants Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines Subpart A, General Provisions Subpart ZZZZ, National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines Subpart AAAAA, National Emission Standards for Hazardous Air Pollutants for Lime
Manufacturing Plants
Table 1 lists the inspection team members.
Team Member Luke Rodriguez
Dawson Bennett
Table 2. PROJECT TEAM MEMBERS
Organization
EPA, Region 7, ECAD, Air Branch Missouri Department of Natural Resources (MoDNR) Southeast Regional Office
FACILITY CONTACT INFORMATION
Table 2 lists the primary facility contacts.
Project Role Lead Inspector
Field team member
Table 3. FACILITY CONTACT INFORMATION
Name, Title
Phone No.
Email Address
Jonathan Kennedy, Environmental and Regulatory Affairs Manager
(573) 883 4309
jmkennedy@mlc.com
Kimberly Bauman, Director of Environmental Affairs
(573) 883 4363
KSLBauman@mlc.com
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FACILITY OVERVIEW
Mississippi Lime Company owns and operates a lime processing plant that is a major and Part 70 (Title V) source for Clean Air Act permitting purposes. Mississippi Lime produces high calcium products that are used in construction, environmental, food and other markets. Limestone is mined, crushed, kiln heated for calcination, hydrated, packaged, and shipped on site. Mississippi Lime Company is a major source for Carbon Monoxide, Hazardous Air Pollutants, Particulate Matter, Sulfur Oxides, Nitrogen Oxides, and Volatile Organic Compounds.
The facility is subject to the following regulations and standards subject to review during this inspection (Table 1):
FACILITY OPERATIONS SUMMARY The Mississippi Lime Company facility is divided into three plants with different kiln types, equipment and control equipment. The first plant is located by the office and is called the Mississippi Rotary Plant. The kilns here are named Mississippi Rotary Kilns 6 -10. Each are considered existing units under 40 CFR 63 Subpart AAAAA and are controlled by wet scrubbers. The second plant is the Vertical Plant. There are 4 vertical lime kilns: Twin shaft Kiln 1 and Single shaft Kilns 1 - 3. These units are not subject to Subpart HH and are controlled by baghouses. The third Plant is the Peerless Plant. This plant is the newest and contains five rotary kilns. These are named Peerless 4, 5 & 6 and Rotary Kilns 1 & 2. One of these kilns at the Peerless Plant is an existing unit and the rest are or will be considered new units under 40 CFR 63 Subpart AAAAA. Peerless 4, 5 & 6 are being rebuilt as part of a construction permit approved by MoDNR Permitting. Those three units will be considered new units when construction is completed. The facility also contains limestone mining and handling equipment subject to 40 CFR 60 Subpart OOO. Much of the 40 CFR 60 Subpart OOO equipment is existing under the Subpart OOO definition. There was a construction permit issued in 2008 for new equipment that is subject to the requirement for a recurring performance test for fugitive emissions. There are currently five reciprocating internal combustion engine units subject to either 40 CFR 63 Subpart ZZZZ, 40 CFR 60 Subpart IIII or 40 CFR 60 Subpart JJJJ.
FIELD ACTIVITIES SUMMARY I arrived at the facility on March 7, 2023, and completed a drive by surveillance inspection at 8:30 AM. The sky was completely overcast, and a determination of opacity or fugitive emissions
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was not possible at that time. I made entry at the front gate and introduced myself and members of the inspection team, presented my credentials, and provided my business card to Mr. Kennedy. I was required to watch the facility safety video as part of the safety briefing. I conducted an opening conference during which I explained that the purpose of the visit was to conduct an inspection to determine compliance with the CAA specifically, to determine compliance with the conditions listed in Table 1. I explained that after asking for some general business information, I would observe work practices, process units, emission units, control equipment and review associated records demonstrating compliance with the regulations listed in Table 1. I explained to Mr. Kennedy that the facility could make a claim of business confidentiality and provided him with a Confidential Business Information form. Mr. Kennedy declined to make a determination of whether to claim of confidentiality at that time and deferred the decision until he had reviewed the information which I requested to be submitted by email. Mr. Kennedy did not make a claim of confidentiality at the time of submittal of the documents on March 16, 2023.
I was given a facility tour by Mr. Kennedy. I wore PPE during the facility tour per my site health and safety plan and in accordance with the facility safety video.
I reviewed the condition of emission units the operating status of the equipment, and any required record keeping for the equipment for compliance with the regulations and permit conditions noted in Table 1 only. I obtained copies of the records as indicated on the Receipt for Documents (Appendix A). I conducted a closing conference with Mr. Kennedy and Mrs. Bauman. I provided the facility with copies of Confidential Business Information form and the Receipt for Documents.
INVESTIGATION OBSERVATIONS AND POTENTIAL FINDINGS
Ambient weather, site conditions and activities were documented in field records. All photographs are attached as Appendix B. I made the following observations during the inspection. I discussed all observations with facility representatives during the closeout meeting unless otherwise noted in the observation description.
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These observations are not final compliance determinations. The EPA Region 7 Air Branch case review team will make the final compliance determinations based on its review of this report and other technical, regulatory, and facility information.
I. 40 CFR 60 Subpart HH - Standards of Performance for Lime Manufacturing Plants
Applicability: The provisions of Subpart HH are applicable to each rotary lime kiln used in the manufacture of lime. Mississippi Lime company is a lime manufacturing plant (LMP) which employs rotary lime kilns in the production of a lime product from limestone by calcination. There are eleven (11) rotary kilns at Mississippi lime company. Eight (8) are currently in use and three (3) are not in use and undergoing reconstruction. Reconstruction of the three rotary kilns was approved by MoDNR in a construction permit. These three kilns will be considered new units upon completion of the reconstruction.
60.342 Standard for Particulate Matter
60.342(a) The rotary lime kilns are subject to a particulate matter emission standard of 0.30 kilograms per megagram (0.60 lb/ton) of stone feed and an opacity limit of 15% when exiting from a dry emission control device. The emission limits in 40 CFR 63 Subpart AAAAA are at least as stringent as those in 40 CFR 60 Subpart HH. Mississippi Lime Company conducts recurring tests of the kilns for compliance with the Subpart AAAAA limits. Testing is completed on a rotating basis with each of the kilns being tested every 5 years. I requested and reviewed the most recent test reports for the units. A discussion of these tests is in the Part 63 Subpart AAAAA section of this report.
60.343 Monitoring of emissions and operations
60.343(a) requires that a subject source install, calibrate, maintain, and operate a continuous monitoring system to monitor and record the opacity of a representative portion of the gases discharged into the atmosphere from any rotary lime kiln. Units which satisfy the criteria in 60.343(b) or (c) are exempt from this requirement.
Mississippi Lime Company operates two rotary kilns with opacity monitors. The systems are spanned at 40% opacity. Mississippi Lime Company uses Teledyne RegPerfect software to
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monitor the opacity from these kilns. Opacity exceedances and monitor downtime are submitted as part of the Semi-Annual Monitoring Reports.
Mississippi Lime Company does not have any units with the equipment configuration in 60.343(b).
Mississippi Lime Company has 6 rotary kilns which use a wet scrubbing emission control device as described in 60.343(c). 60.343(c) requires the source to install, calibrate, maintain, operate, and record the resultant information from a monitoring device for the continuous measurement of the pressure loss of the gas stream through the scrubber and a monitoring device for continuous measurement of the scrubbing liquid supply pressure to the control device. Mississippi Lime Company buys certified differential pressure gauges and flow monitors. These become lime scaled on a regular basis and Mississippi Lime Company maintains a surplus of these and orders more when the supply is low.
60.343(d) requires the installation, calibration, and maintenance of a device for measuring the mass rate of stone feed to any affected rotary lime kiln. Mississippi Lime Company uses a conveyor with a scale for each rotary kiln. These were calibrated during initial installation. 60.343(e) requires periods of excess emissions be reported. Excess emissions are defined as all 6-minute periods during which the average opacity of the visible emissions from any lime kiln subject to Subpart HH, greater than 15 percent or, in the case of wet scrubbers, any period in which the scrubber pressure drop or scrubbing liquid supply pressure is greater than 30 percent below that established during the performance test.
Mississippi Lime Company uses a RegPerfectTM software for tracking the 6-minute average opacity. Mississippi Lime Company has not reported any exceedances of the opacity standard during 2022. These units also have bag-leak detection alarm systems. According to Mr. Kennedy, the bag leak detection systems are more sensitive, and the protocols enacted during an alarm generally preclude getting to the point of an opacity exceedance. Mississippi Lime Company also monitors the scrubber pressure drop and flow for the Mississippi rotary kilns. They reported 0 exceedances during 2022. Monitoring Reports for these requirements are submitted semi-annually in the EPA's central data exchange (CDX).
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II. 40 CFR 60 Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
Applicability: The provisions of Subpart OOO are applicable to each crusher, grinding mill, screening operation, bucket elevator, belt conveyor, bagging operation, storage bin, enclosed truck or railcar loading station in fixed or portable nonmetallic mineral processing plants. According to 60.670(a)(2), the provisions of this subpart do not apply to facilities located in underground mines. Mississippi Lime Company operates an underground limestone mine. The equipment in that location is not subject to this subpart.
60.672 Standard for particulate matter (PM).
60.672(a) Affected facilities must meet the stack emission limits and compliance requirements in Table 2 of 40 CFR 60 Subpart OOO. The requirements in Table 2 of this subpart apply for affected facilities with capture systems used to capture and transport particulate matter to a control device. The particulate matter standard for equipment that commenced construction, modification, or reconstruction after August 31, 1983, but before April 22, 2008, is 0.05 g/dscm and 7 percent opacity for dry control devices. The particulate matter standard for equipment that that commenced construction, modification, or reconstruction on or after April 22, 2008, is 0.032 g/dscm and 7 percent opacity for dry control devices on individual enclosed storage bins.
Mississippi Lime Company completed its initial testing in February of 1999. In 2008, Mississippi Lime Company was issued a Construction Permit to construct a new aggregate processing plant for the Peerless Mine. Most of that equipment was constructed inside the mine and thus not subject to the emission limits in Subpart OOO. The portion built above ground consisted of three new conveyor transfer points. Maximum hourly production of this equipment was achieved in 2010 and a test was completed in March 2010. Both the 1999 and 2010 test successfully demonstrated emission rates below the Table 2 standards. These tests are included as Appendix C.
60.672(b) Affected facilities must meet the fugitive emission limits and compliance requirements in Table 3 of 40 CFR 60 Subpart OOO. The requirements in Table 3 of this subpart apply for fugitive emissions from affected facilities without capture systems and for fugitive emissions escaping capture systems. Table 3 specifies a fugitive opacity limit for grinding mills, screening operations, bucket elevators, transfer points on belt conveyors, bagging operations,
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storage bins, enclosed truck or railcar loading stations of 10 percent for units that commenced construction, modification, or reconstruction after August 31, 1983, but before April 22, 2008, and 7 percent for units that commenced construction, modification, or reconstruction on or after April 22, 2008. Crushers which do not use a capture system must meet a 15 percent or a 12 percent limit depending on the date they commenced construction. An initial performance test is required for all units, but a repeat performance test is required every 5 years for those units which commenced construction after April 22, 2008. The most recent test conducted for the new post 2008 equipment was conducted on May 6, 2020. The deadline for the next test is May 31, 2025. These tests are included in Appendix C.
60.672(e) requires that affected facilities which are enclosed within a building comply with fugitive emissions limit including 7 percent opacity and the appropriate stack emission limit in Table 2 depending on the date of construction. The facility does not have any 40 CFR 60 Subpart OOO equipment which is located inside an enclosed building.
Mississippi Lime Company does not have any baghouses which control emissions from an individual enclosed storage bin.
60.674 Monitoring of operations.
60.674(a) & (b)- Mississippi Lime Company does not use a wet scrubber or a wet suppression system to control emissions for any of its affected Subpart OOO equipment.
60.674(c), requires quarterly Method 22 tests. Mr. Kennedy told me that the facility does not have any equipment for which construction, modification, or reconstruction commenced on or after April 22, 2008, which is controlled by a baghouse.
60.674(d) specifies an alternative to the periodic Method 22 observations. Mississippi Lime Company does not maintain any bag leak detection systems on a baghouse which controls its Subpart OOO equipment.
III. 40 CFR 60 Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines & 40 CFR 63 Subpart ZZZZ - National Emissions
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Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines
Mississippi Lime Company has 5 emergency engines. Two were installed in 2015. The June 30, 2018, Operating Permit lists one as diesel fired and the others as natural gas fired with both being subject to 40 CFR 60 Subpart IIII. Natural Gas units are not typically compression ignition and therefore EU9999 is most likely subject to 40 CFR 60 Subpart JJJJ. The three remaining engines are older units subject only to 40 CFR 63 Subpart ZZZZ. Mr. Kennedy tracks the annual hours of operation for these units. The units appear to be used in compliance with the usage requirements and hour limitations located in 63.6640(f), 60.4243(d) or 60.4211(f) as applicable. Mississippi Lime Company maintains a contract with Cummins to conduct recurrent maintenance on the units. The maintenance conducted on the units appears to comply with the requirements located in Table 2C to 40 CFR 63 Subpart ZZZZ, 60.4243 or 60.4211 as applicable. See Appendix D for the 2 MRK Engine Cummins Maintenance form completed in October 2022.
IV. 40 CFR 63 Subpart AAAAA - National Emission Standards for Hazardous Air Pollutants for Lime Manufacturing Plants
Applicability: Each existing or new lime kiln(s) and its associated cooler(s) and processed stone handling (PSH) operations system(s) located at an LMP that is a major source.
Mississippi Lime Company is a Lime Manufacturing Plant that is a major source.
There are 15 total lime kilns at Mississippi Lime Company; 9 are existing and 6 are new. These are divided between 3 sections of the plant. There are the 6 Mississippi Rotary Kilns, 5 Peerless Rotary Kilns and 4 Vertical Kilns. 3 of the 5 Peerless Kilns are currently in the process of reconstruction. This reconstruction was approved by MoDNR permitting and will result in these units becoming new for the purposes of Subpart AAAAA. A summary of the units and their requirements are listed below.
Table 4. SUMMARY OF MISSISSIPPI LIME COMPANY KILNS PM EMISSION STANDARDS
Emission limit in Table 1 to
Kiln
New or Existing
Subpart AAAAA
(Peerless Plant) Rotary Kiln # 1 Twinshaft Vertical Kiln
Singleshaft Vertical Kiln #1
Existing and not equipped with a wet scrubber
Subject to #1. In Table 1: 0.12 lbs/tsf (ton of stone feed)
6 Mississippi Rotary Kilns
Existing and equipped with a wet scrubber
Subject to #2. In Table 1: 0.60 lb/tsf.
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(Peerless Plant) Rotary Kiln #2 Singlshaft Kilns #1 & #2 New
Peerless Rotary Kilns 4, 5 & 6 (Undergoing reconstruction)
Subject to #3. In Table 1: 0.10 lb/tsf.
Each Rotary Kiln has a cooler. Cooler emissions are routed back into the Kiln. The 6 Mississippi Rotary Kilns have a processed stone handling operation system (PSH) that consists of 1 bin and conveyor each. No other kiln has a PSH. Tests are required every 5 years. Each unit is on a different testing schedule. The most recent tests which occurred for each category of Kiln are as follows: Peerless Rotary Kiln No. 1. completed a successful test on March 8, 2020, Single Shaft Vertical Kiln No. 3. completed a successful test on February 7, 2022, and Mississippi Rotary Kilns 7 & 8 completed a successful test on September 21, 2022. These tests are included as Appendix C.
Operating limits are specified in Table 3 of Subpart AAAAA. The two Peerless Rotary Kilns and the 4 Vertical Kilns are equipped with fabric filters. The 4 vertical kilns use bag leak detection systems as under #1 in Table 3 of Subpart AAAAA. The total alarm condition as a percent of the operating time is included in the semi-annual reports which are submitted through CDX. Mississippi Lime Company reported that the alarm condition did not exceed 5 percent of the total operating time at any point during 2022. The 2 Peerless Rotary Kilns are equipped with continuous opacity monitors (COMs). 6-minute averages are calculated by RegPerfect software. Any excessive 6-minute averages are reported in the semi-annual reports. Mississippi Rotary Kilns 5 - 10 are equipped with wet scrubbers as in #2 in Table 3 of Subpart AAAAA. Mississippi Lime Company records the 3-hour block gas stream pressure drop across the wet scrubber and the 3-hour block scrubbing liquid flow rate. Mississippi Lime Company reported no deviations from either operating limit during 2022. The most recent annual and quarterly COMS audit and calibrations for Rotary Kilns 1 and 2 (Peerless 1 & 2) and the Singleshaft Kiln 1 and the Twinshaft Kiln (Vertical Kilns) are attached as Appendix E.
Row number 8 in Table 3 of Subpart AAAAA requires an Operation Monitoring and Maintenance Plan. Mississippi Lime Company maintains 3 different OM&M Plans - one for the Mississippi Rotary Plant, one for the Peerless Rotary Plant and one for the Vertical Kiln Plant. These plans are included as Appendix F. Each plan must include the items listed in 63.7100(d)(1) - (7).
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Table 5. EVALUATION OF OM&M PLAN REQUIREMENTS
Citation and Requirement
Comments on OM&M Plan
63.7100(d)(1) Process and control device parameters The OM&M Plans provided by the facility do not
to be monitored to determine compliance, along with record the device parameters to be monitored or the
established operating limits or ranges, as applicable,
established operating limits or ranges for each emission
for each emission unit.
unit. The plans have not been updated since 2009.
63.7100(d)(2) A monitoring schedule for each
The three OM&M Plans contains a monitoring
emission unit.
schedule for each emission unit.
63.7100(d)(3) Procedures for the proper operation
and maintenance of each emission unit and each air
The OM&M Plans contains procedures for the
pollution control device used to meet the applicable
operation and maintenance of the units, PSH
emission limitations and operating limits in Tables 1, 2 equipment and air pollution control equipment.
and 3.
63.7100(d)(4) Procedures for the proper installation, operation, and maintenance of monitoring devices or systems used to determine compliance, including:
(i) Calibration and certification of accuracy of each monitoring device;
(ii) Performance and equipment specifications for the sample interface, parametric signal analyzer, and the data collection and reduction systems;
(iii) Prior to the relevant compliance date for your source as specified in 63.7083(e), ongoing operation and maintenance procedures in accordance with the general requirements of 63.8(c)(1)(i) and (ii), (3), and (4)(ii). On and after the relevant compliance date for your source as specified in 63.7083(e), ongoing operation and maintenance procedures in accordance with the general requirements of paragraph (c) of this section and 63.8(c)(1)(ii), (3), and (4)(ii); and
The OM&M Plans includes information on the calibration and operation of monitoring equipment.
(iv) Ongoing data quality assurance procedures in accordance with the general requirements of 63.8(d). 63.7100(d)(5) Procedures for monitoring process and control device parameters
63.7100(d)(6) Corrective actions to be taken when process or operating parameters or add-on control device parameters deviate from the operating limits specified in Table 3 to this subpart, including:
(i) Procedures to determine and record the cause of a deviation or excursion, and the time the deviation or excursion began and ended; and
The OM&M Plans contains procedures for monitoring the control device parameters.
The OM&M Plans contain a procedure for taking corrective actions and procedures for the determination of the cause of the deviation or excursion.
(ii) Procedures for recording the corrective action taken, the time corrective action was initiated, and the time and date the corrective action was completed.
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63.7100(d)(7) A maintenance schedule for each emission unit and control device that is consistent with the manufacturer's instructions and recommendations for routine and long-term maintenance.
Each OM&M Plan mentions that maintenance on the units is conducted in accordance with the manufacturer recommendations but does not include a schedule for any unit nor identify any specific maintenance activities. Mississippi Lime Company was able to provide a maintenance schedule in spreadsheet format for the baghouses.
63.7100(e) requires a written startup, shutdown, and malfunction plan (SSMP). The OM&M Plans attached as Appendix F also include SSM Plans. These plans are consistent with the provisions in 63.6(e)(3). Sample monthly maintenance activities conducted on the Peerless Rotary Kilns 1 and 2 are attached as Appendix G. The list of preventative maintenance work orders for these kilns are attached as Appendix H.
63.7120 How do I monitor and collect data to demonstrate continuous compliance?
During 2022, Mississippi Lime Company reported 0% monitor downtime. This information is included in the two Semi-Annual Monitoring Reports submitted to CDX.
Table 6 and 7 to Subpart AAAAA specify requirements for the methods to be used in documenting continuous compliance with the emission limitations in Tables 1 and 3 of Subpart AAAAA. Most of these requirements are also specified elsewhere in the regulation and are addressed above.
Number 1 in Table 7 requires conducting a monthly 1-minute VE check of each PSH operation subject to an opacity limit. Consecutive VE checks with no opacity allow a less frequent monitoring schedule. Currently, Mississippi Lime Company is conducting these VE checks semi-annually. These VE checks are included as Appendix I.
Potential Finding 1: The OM&M Plans do not have all of the required information. Observation Summary: OM&M Plans do not contain the device parameters to be monitored or the established operating limits or ranges. Citation: 63.7100(d)(1) Evidence: Photo 3 of Appendix B and Appendix F Description of Observation: The OM&M Plans provided by the facility do not record the device parameters to be monitored or the established operating limits or ranges for each emission unit. The plans have not been updated since 2009. This is most likely since testing occurs on a rotating basis and that updates to the plan would be required frequently. An appendix which contains this updated information could be referenced by the OM&M Plan.
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