Document bRaNNVmRxne313O6MVdqRwOD

SUBJECT: FROM: THRU: TO: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 CLEAN AIR ACT INSPECTION REPORT Fairborn Cement Company, Xenia, Ohio Valeria Apolinario, Environmental Engineer AECAB (MN-OH) Charles Hall, Environmental Engineer AECAB (MN-OH) Brian Dickens, Section Chief AECAB (MN-OH) File, Fairborn Cement Company, Xenia, Ohio BASIC INFORMATION Facility Name: Fairborn Cement Company (FCC) Facility Location: 3250 Linebaugh Road, Xenia, Ohio Dates of Inspection: August 23 and 24, 2022 EPA Inspectors: 1. Valeria Apolinario 2. Charlie Hall Other Attendees: 1. Tom Byrne, Environmental Manager 2. Jeremy Cooper, CEM Technician 3. Tom Fife III, Maintenance Supervisor - Dust Collectors 4. John Miller, V.P. of Operations 5. Brett Silcott, Kiln Control Room Operator 6. Alex Winner, Process Engineer Contact Email Address: tbyrne@fairborncement.com Purpose of Inspection: To determine compliance with the National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry (the PC MACT) and Title V Permit. Facility Type: Portland and masonry cement plant Regulations Central to Inspection: Portland Cement MACT and Title V Permit Date: Arrival Time: Departure Time: August 23, 2022 0845 hrs EDT 1600 hrs EDT August 24, 2022 0825 hrs EDT 1145 hrs EDT Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided because assets are greater than $25.0 million. Provided CBI warning to facility The following information was obtained verbally from Tom Byrne unless otherwise noted. Miller joined the inspection for the opening conference on the first day and briefly on the second day. Cooper joined the inspection to show the continuous emission monitoring equipment to the inspectors. Fife and Winner accompanied the inspectors on the plant tour. Fife also participated in the records review on the second day. Silcott supplied the PC MACT continuous monitoring system data. Company Ownership: The ownership has not changed in the last 5 years. Process Description: FCC mines limestone and clay from an on-site quarry and crushes them in separate equipment into softball-sized or smaller pieces. The limestone is stored in a large open-air shed. FCC adds the clay to limestone which are then fed together to the raw mill where the clay and limestone are ground together to the fineness of talcum powder. The resulting mixture is pneumatically conveyed to the top of the four-stage pre-heater tower. As the limestone, which is primarily calcium carbonate, and clay flow down the pre-heater tower, carbon dioxide disassociates from the calcium carbonate. The pre-heated mixture is fed to the cold end of the rotary kiln. FCC burns coal in burners in the hot end of the kiln. FCC's primary fuel is pulverized coal but also uses natural gas and pet coke as fuel. FCC has used fuel oil in the past. Cement clinker exits the kiln to the clinker cooler and is then stored in the clinker dome. FCC grinds the cement clinker in the finish mill. The final product is stored in silos and loaded into trucks. FCC has numerous fabric filters to control particulate matter emissions. Among other locations, FCC has fabric filters to control emissions from the limestone crushing equipment, the limestone storage conveyor, the kiln feed building, the clinker cooler, the clinker storage, the coal storage building, the finishing mill, and the loading terminal. FCC utilizes activated carbon injection to control for mercury emissions, lime spray injection to control for SO2 emissions, and ammonia reagent injection to control for NOx emissions from the main stack. Lime spray is also injected in the alkali bypass stack. Page 2 of 7 The PC MACT and/or the Title V permit require(s) FCC to monitor the following parameters continuously: raw material feed rate, total hydrocarbon emissions, kiln baghouse site-specific particulate matter continuous parameter monitoring system (PM CPMS) parameter, clinker cooler baghouse site-specific PM CPMS parameter, sulfur dioxide (SO2) concentration, oxides of nitrogen (NOx) concentration, kiln exhaust gas temperature, ammonia reagent injection rate, and alkali bypass exhaust gas temperature. The PC MACT and Title V permit require FCC to demonstrate compliance by operating a mercury CEMS or a sorbent trap based CEMS. FCC uses the mercury sorbent trap CEMS to demonstrate compliance. However, FCC also installed, operates, calibrates, and maintains a mercury CEMS to provide continuous monitoring. Staff Interview: Miller and Byrne provided a set of diagrams that illustrate the major steps of the process. The diagrams are attached. Miller and Byrne stated that FCC analyzes process feedstocks for magnesium, sulfur, and total hydrogen carbons to keep their concentrations low. High magnesium concentrations in the feedstocks will adversely affect product quality. Mercury is not an issue from limestone and clay. Coal is the source of mercury, and the mercury concentration is a specification in the purchase contract. They also stated that hydrogen chloride and SO2 will cause clogs in the pre-heater tower. During the plant tour, in response to a question from Hall, Byrne answered that a ring of cement clinker will form within the kiln once or twice per year. The limestone crushers are inside a building. A horizontal conveyor under the crusher transports the crushed limestone to an inclined conveyor. Fabric filter B10 collects PM from inside the crusher building. Fabric filter B49 collects PM that emits from the inclined conveyor. During the plant tour, the inspectors observed a cloud of PM outside of the crusher building. See pictures 3, 4, and 5 below. Byrne noted that FCC believes B49 is undersized for the crushed and has scheduled its replacement with a fabric filter that will double the volumetric flow rate to 10,000 cubic feet per minute. The inspectors observed fugitive dust at the Transfer Tower Hopper (picture 7). Byrne explained that FCC was conducting maintenance to clean the conveyor belt at transfer points. From the top of the pre-heater tower, the inspectors observed PM emitting from the Finish Mill (picture 14). During the second day of the inspection, FCC replaced two leaking bags in the Finish Mill's fabric filter. Byrne provided a copy of the work order. FCC has ordered the bags to replace all 500 bags in the Finish Mill's fabric filter. However, the project has been delayed until February 2023 due to supply chain problems. FCC has a few replacement bags as needed. On the second day of the inspection, Apolinario collected visible emission data for the Finish Mill. The VE data is attached. The recently completed cement dome has an automated cement loading system. The current cement loading system has a manually operated cement loading system. Consequently, numerous drivers translate into a large variation in the attentiveness to procedures and resulting fugitive dust emissions. As the inspectors were getting into the car to leave at the end of the first day of the inspection, they observed a plume of black dust above the kiln and followed it back to the carbon injection system where a crew of workers was performing maintenance work. See pictures 16 through 19. TOUR INFORMATION EPA Tour of the Facility: Yes Page 3 of 7 Data Collected and Observations: The inspectors collected the following operating and emission data: Parameter Raw Material Feed Rate Total Hydrocarbon THC 1-day rolling average THC 1-minute average Kiln Baghouse Site-Specific PM CPMS Parameter Clinker Cooler Baghouse Site-Specific PM CPMS Parameter SO2 NOx Ammonia Injection Rate Dioxin/Furan Parameters Kiln Exhaust Gas Temperature Alkali Bypass Exhaust Gas Temperature Mercury CEM3 Hydrogen Chloride4 Set Value, Units 146.4 tons per hour, 1-minute average 28.5 ppmV, 30-day rolling average No emission standard No emission standard 6.0 mA, 30-day rolling average Actual, Units 145.8 tons per hour, 1-minute average 24.6 ppmV, 30-day rolling average 25.2 ppmV 1.1 ppmV 0.9 mA, 30-day rolling average 6.4 mA, 30-day rolling average 0.1 mA, 30-day rolling average 1.1 pound per ton of cement clinker, 30-day rolling average 1.85 pounds per ton of cement clinker, 30-day rolling average Not available3 348F raw mill on 547F raw mill off 496F raw mill on or off 55 pounds per million tons of cement clinker 95.0 ppm wet, 30-day rolling average 0.930 pounds pr ton, 30-day rolling average 1.76 pounds per ton of cement clinker, 30-day rolling average 5.9 gallons per minute Not available1 Not available2 10.2 pounds per million tons of cement clinker 19.7 ppm wet, 30-day rolling average Photos were taken during the inspection. Field Measurements: were taken during the inspection. Visible emission data sheet attached. RECORDS REVIEW During the inspection, the inspectors reviewed example Reference Method 22 data. Requested documents: The inspectors requested the following documents during the inspection: 1 The inspectors reached the control room at approximately 1400 hrs. This temperature would not be available until 1630 hours. The data will populate the operator's screen when available. 3 The Title V Permit does not require a set value to be established for the ammonia injection rate. 2 This average resets when the raw mill status changes. 3 FCC uses mercury traps to determine compliance. It uses the mercury CEM to track the trend of its mercury emissions. 4 As the PC MACT allows, FCC measures SO2 as surrogate for HCl. The regulatory limit is re-set every 30 months. Page 4 of 7 - Facility Map Overview - Facility Processes Overview (12 overall pages) - Examples of Daily Finish Mill Method 22 Reading (8/5/2022, 8/19/2022, and 8/23/2022) - Monthly Method 22 Example from April 1, 2022, on Cement Elevator to Finish Mill Baghouse - Communications with RAPCA about utilizing additional PM injections during PM performance test including o Letter from Andrew Weisman approving additional PM injections on a conditional basis o Kiln and Cooler Test Report Follow-Up emails between Chelsea Villalba (Fairborn Plant Environmental Manager) and Jennifer Riley (RAPCA) o Memo from Chelsea Villalba to the facility that RAPCA authorized removal of opacity monitors from service - Notice of Intent to perform PM and D/F Tests dated September 3, 2014 - Sampling Protocol for D/F testing to occur May 1-5, 2017 - Title V Emissions Report for 2021 - D/F Report for Test Dates July 25-26, 2019 - D/F Report for Test Dates January 25-27, 2022 - Sampling Protocol for D/F Testing to occur January 25-26, 2022 - Q1, Q2 Title V Deviation Reports 2022 - Q3, Q4 Title V Deviation Reports 2021, - Dust Collector Inspection Checklist - Daily Visible Emissions (Y/N) documentation from 8/24/2021-8/23/2022 - Annual Greenhouse Gas Report for 2021 Concerns: The inspectors identified four concerns: 1. Dioxin/Furan Monitoring Because FCC is subject to a dioxin/furan emission standard and because FCC uses activated carbon injection, FCC must demonstrate compliance with the activated carbon injection rate operating limits specified in 63.1346 by using the performance test methods and procedures in 63.1349(b)(3)(v). See 40 C.F.R. 63.1348(a)(3)(iii). Consequently, the PC MACT requires FCC to maintain a 3-hour rolling average carbon injection feed rate and either a carrier fluid flow rate or pressure drop and to install, operate, calibrate, and maintain a continuous monitor to record the activated carbon injection system carrier gas parameter (either the carrier gas flow rate or the carrier gas pressure drop). See 40 C.F.R. 63.1350(h), (h)(1), (h)(2), (m)(4) and (m)(9). There was no indication that these obligations were being met. 2. Plastic Strip Curtains at Doors The Title V permit requires FCC to have plastic strip curtains at the tunnel entrance/exit of the limestone crusher which is emission unit P901. The inspectors found them missing. 3. Black Dust Plume On August 23, 2022, as the inspectors were about to get into the car, Mr. Hall noticed a black dust plume behind the kiln. He followed the plume back to the carbon injection equipment. The inspectors showed the picture to Mr. Byrne and Mr. Miller on August 24, 2022. Page 5 of 7 4. Opacity at Finishing Mill was 11.67% (3-minute average). On August 24, 2022, Apolinario collected visible emission data for the Finishing Mill. The visible emission standard for that source is 10% as 3-minute average. FCC had replaced two bags that morning. The Environmental Manager stated he believes that the collector is still blowing out dust that was in the top plenum. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility DIGITAL SIGNATURES Digitally signed by CHARLES CHARLES HALL HALL Date: 2022.09.28 09:13:38 -05'00' Report Author: Digitally signed by Brian Dickens Brian Dickens Date: 2022.09.28 13:04:59 -05'00' Section Chief: Page 6 of 7 Facility Name: Fairborn Cement Company Facility Location: 3250 Linebaugh Road, Xenia, Ohio Date of Inspection: August 23 and 24, 2022 APPENDICES AND ATTACHMENTS A. Digital Image Log B. Visible Emission Sheet Page 7 of 7 Facility Name: Fairborn Cement Company Facility Location: 3250 Linebaugh Road, Xenia, Ohio Date of Inspection: August 23 and 24, 2022 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Valeria Apolinario 2. Archival Record Location: R5 Electronic Records Center Camera: Olympus TG-1 Equipment Number: SZ4061 Image Number 1 2 File Name P8230005.jpg P8230006.jpg Date and Time (incl. Time zone and DST) 2022:08:23 06:25:28 2022:08:23 08:01:55 Description of Image Fairborn Cement Entrance Sign Clay Additive Building Appendices Page 1 of 11 Facility Name: Fairborn Cement Company Facility Location: 3250 Linebaugh Road, Xenia, Ohio Date of Inspection: August 23 and 24, 2022 Image File Name Date and Time (incl. Number Time zone and DST) 3 P8230007.jpg 2022:08:23 08:02:40 Description of Image Visible Emissions from Limestone Crusher 4 P8230008.jpg 2022:08:23 08:05:59 Limestone Crusher Adjacent to Beginning of Lime Conveyor System Appendices Page 2 of 11 Facility Name: Fairborn Cement Company Facility Location: 3250 Linebaugh Road, Xenia, Ohio Date of Inspection: August 23 and 24, 2022 Image File Name Date and Time (incl. Number Time zone and DST) 5 P8230009.jpg 2022:08:23 08:08:26 Description of Image Visible Emissions from B49 Dust Collector 6 P8230010.jpg 2022:08:23 08:10:56 Lime Conveyor Transfer Line Appendices Page 3 of 11 Facility Name: Fairborn Cement Company Facility Location: 3250 Linebaugh Road, Xenia, Ohio Date of Inspection: August 23 and 24, 2022 Image File Name Date and Time (incl. Number Time zone and DST) 7 P8230011.jpg 2022:08:23 08:13:25 Description of Image Transfer Tower Hopper Maintenance Malfunction 8 P8230012.jpg 2022:08:23 08:14:47 Clay Transfer Point Appendices Page 4 of 11 Facility Name: Fairborn Cement Company Facility Location: 3250 Linebaugh Road, Xenia, Ohio Date of Inspection: August 23 and 24, 2022 Image File Name Date and Time (incl. Number Time zone and DST) 9 P8230013.jpg 2022:08:23 08:22:52 Description of Image Limestone Tower with Additive Towers 10 P8230014.jpg 2022:08:23 08:23:45 Collection Point of Additives, Clay, and Lime to be Sent to Raw Mill Appendices Page 5 of 11 Facility Name: Fairborn Cement Company Facility Location: 3250 Linebaugh Road, Xenia, Ohio Date of Inspection: August 23 and 24, 2022 Image File Name Date and Time (incl. Number Time zone and DST) 11 P8230015.jpg 2022:08:23 08:29:29 Description of Image Conveyor X-Ray Fluorescence Monitor 12 P8230016.jpg 2022:08:23 08:35:47 Plastic Strip Curtains at Limestone Crusher Appendices Page 6 of 11 Facility Name: Fairborn Cement Company Facility Location: 3250 Linebaugh Road, Xenia, Ohio Date of Inspection: August 23 and 24, 2022 Image File Name Date and Time (incl. Number Time zone and DST) 13 P8230017.jpg 2022:08:23 08:35:56 Description of Image Plastic Strip Curtains at Limestone Crusher Appendices Page 7 of 11 Facility Name: Fairborn Cement Company Facility Location: 3250 Linebaugh Road, Xenia, Ohio Date of Inspection: August 23 and 24, 2022 Image File Name Date and Time (incl. Number Time zone and DST) 14 P8230018.jpg 2022:08:23 09:21:52 Description of Image Visible Emissions at Finish Mill 15 P8230019.jpg 2022:08:23 11:51:46 Inside of Clinker Storage Appendices Page 8 of 11 Facility Name: Fairborn Cement Company Facility Location: 3250 Linebaugh Road, Xenia, Ohio Date of Inspection: August 23 and 24, 2022 Image File Name Date and Time (incl. Number Time zone and DST) 16 P8230020.jpg 2022:08:23 13:37:11 Description of Image Back of Finish Mill 17 P8230021.jpg 2022:08:23 13:37:36 Activated Carbon Plume Appendices Page 9 of 11 Facility Name: Fairborn Cement Company Facility Location: 3250 Linebaugh Road, Xenia, Ohio Date of Inspection: August 23 and 24, 2022 Image File Name Date and Time (incl. Number Time zone and DST) 18 P8230022.jpg 2022:08:23 13:38:09 Description of Image Activated Carbon Injection Maintenance 19 P8230023.jpg 2022:08:23 13:38:14 Activated Carbon Maintenance, Plant View Appendices Page 10 of 11 Facility Name: Fairborn Cement Company Facility Location: 3250 Linebaugh Road, Xenia, Ohio Date of Inspection: August 23 and 24, 2022 APPENDIX B: VISIBLE EMISSION DATA Appendices Page 11 of 11 COMPANY NAME VISIBLE EMISSION OBSERVATION FORM No. STREET ADDRESS - \pJ LG cm, I $IAj ZIP PHONE (KEY CONT PROCESS EOUIPMEHT SOURCE ID NUMBER O2cr1OtJI( I OPERATING MOD! CbNTROI. EOUIPMEP& V. 6-x,'- DESCRIBE EAISSION POINT XV4. J'\\, II OPEFWIING MODE HEIGHT ABOVE GROUND LEVEL I HEIGHT RELATIVE TO OBSERVER k{*- U23 1-j s rL 0 DISTANCE FROM OBSERVER DIRECTION FROM OBSERVER Stan PC)O'td OO + Start End }J J DESCRIBE EMISSIONS Start 5ii)(L* I EMISSiON COLOR F WATER DROPLET PWME Stan End 1J\' aco Detached 0 POINT IN THE PLUME AT WHICH OPACITY WAS DETERMINED Stan O\'Qb( QX End ()(3\C ' DESCRIBE PWME BACKGROUND BACKGROUND COLOR Start LA-2_.End WINO SPEED Stan End AMBIENT TEMP Stan \) 0 too\ suc3 SKY CONOmflONS. stak End WIND DIRECTION (3 t-)c st \P Start ( /'sJt/'J End (3 t3F WET BULB TEM,. I RH. percent . qo- Stactc Wth Plume Sun Wind 4- --- SOURCE LAYOUT SKETCH Draw Norm Mrow I\ mIaaion Point Obeerve,a Pcli Sun ADomoNAl. INFORMATION c(( L \cX (A\QCi O\3 I OBSERVERS NAME (PRINT) I cf(k\ecS OBSERVERS 0' -orTO DATE CERTIFIED BY L4\- Y [N11NUEO ON VEO FORM NUMBER / ) 7_ II