United States Office of Air Quality Planning EPA-340/1 -83-021
Environmental Protection and Standards April 1983
Agency Washington DC 20460
Stationary Source Compliance Series
Development of
Pilot Inspection
System for
Virginia State
Air Pollution
Control Board
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EPA-340/1-83-021
Development of Pilot
Inspection System for Virginia State
Air Pollution Control Board
by
PEDCo Environmental, Inc.
11499 Chester Road
Post Off ice Box 46100
Cincinnati, Ohio 45246-0100
Contract No. 68-01-6310
Work Assignment No. 28
PN 3560-1-28
EPA Project Officer: John R. Busik
Task Manager: Gerald Lappan
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Stationary Source Compliance Division
401 M Street, S.W.
Washington, D.C. 20460
April 1983
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DISCLAIMER
This report was prepared by PEDCo Environmental, Inc., Cincinnati, Ohio,
under Contract No. 68-01-6310, Work Assignment No. 28. It has been reviewed
by the Stationary Source Compliance Division of the Office of Air Quality
Planning and Standards, U.S. Environmental Protection Agency and approved
for publication. Approval does not signify that the contents necessarily
reflect the views and policies of the U.S. Environmental Protection Agency.
Mention of trade names or commercial products is not intended to constitute
endorsement or recommendation for use. Copies of this report are available
from the National Technical Information Service, 5285 Port Royal Road,
Springfield, Virginia 22161.
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CONTENTS
Figures
Tables
Acknowledgment
1. Introduction 1
Purpose and scope 2
Goals 2
2. Description of the Study 5
Geographic area 5
Sources and emissions 7
Organization and personnel 7
Source compliance status 11
Region II inspection procedures prior to the study 12
Summary of past inspections 12
3. Methodology 15
Classroom 15
Field training 18
Targeting plan 20
Analysis of results 25
4. Results 31
Targeting/modified inspection plan 31
Inspections conducted 32
Attitude of the inspector 55
Attitude of industry concerning comprehensive inspections 60
Agency approach to continuing compliance 61
Resources required to implement comprehensive inspections 61
Impact on air quality 62
Impact on emissions 63
5. Conclusions and Recommendations 65
Conclusions 65
Recommendations 66
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CONTENTS (continued)
Appendix A CDS output for the Valley of Virginia
Appendix B Summary of compliance status for sources in Region II
Appendix C Source inspection report form
Appendix D Example of inspection reports completed prior
to the study
Appendix E Agenda for Roanoke classroom instruction
Appendix F Workshop examination
Appendix G Equipment check list
Appendix H Recommended targeting plan
Appendix I Example of inspection reports prepared as a result of
implementing modified inspection plan
Appendix J Letters from industry
Appendix K Summary of changes in inspection procedures as a
result of the study
Appendix L Letters from Regional Director and Director of
Compliance
Appendix M Selected case histories
K-l
L-l
M-l
iv
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FIGURES
Number Page
1 Virginia Air Quality Control Regions and Regional Offices 6
2 Example of Form Used to Summarize Information Obtained from
File Review and Discussions with Inspectors 26
3 Example of Targeting Plan Tables 27
4 Inspector Interview Form 29
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TABLES
Number Page
1 Valley of Virginia Particulate Matter Emissions 8
2 Job Title, Educational Level, and Experience of
Inspectors in Region II 11
3 Region II Modified Inspection Plan 33
4 Results of Virginia Pilot Study - Level 3 Inspections 47
5 Summary of Inspections Using Level 3 Methods 54
6 Summary of Inspector Responses 57
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ACKNOWLEDGMENT
This report was prepared for the U.S. Environmental Protection Agency by
PEDCo Environmental, Inc., Cincinnati, Ohio. Mr. John Busik was the EPA
Project Officer. Mr. George Jutze served as the Project Director, and
Mr. Ronald Hawks was the Project Manager. The principal authors were
Mr. Ronald Hawks, Mr. Gary Saunders, and Mr. David Dunbar. The authors wish
to thank the Commonwealth of Virginia Air Pollution Control Board for its
cooperation in conducting this study. In particular, the authors would like
to thank Mr. William Jewell, Director of the Division of Compliance,
Mr. Donald Shepherd, Director of Region II, and the inspectors in Region II
for their interest and effort in completing this study.
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SECTION 1
INTRODUCTION
Over the past several years considerable concern has been raised within
the air pollution control community as to whether sources are properly operat-
ing and maintaining their control equipment. Some concern has also been
raised regarding whether sources are complying with the applicable emission
limits on a continuous basis. In many cases sources can fine-tune their con-
trol systems and make the necessary adjustments to comply with the emission
limits during stack tests conducted to certify compliance with the applicable
emission limits. Once these tests have been completed, however, the control
efficiency of the systems may begin to deteriorate and sources may no longer
have ongoing incentives to be in compliance with the applicable emission
limit.
Reasons for the possible deterioration of the control system efficiency
include lack of good operation and maintenance (O&M) procedures, poor or
virtually no maintenance, poor design, lack of understanding on the part of
the control equipment operator, lack of reliable instrumentation, poor record-
keeping, and little or no evaluation of the records that are kept.
Failure of sources to maintain continuing compliance is a matter of deep
concern to State and local agency officials because it can affect their ability
to attain and maintain National Ambient Air Quality Standards (NAAQS). Thus,
many State and local agencies are looking for ways to improve their surveil-
lance, inspection, and enforcement programs to encourage source owners to
operate and maintain their control equipment properly, to maintain adequate
records and to use these records to avoid significant operating problems,
and to comply with all applicable emission limits and visible emission stan-
dards on a continuing basis.
Several States have expressed concerns over continuing compliance but
the Commonwealth of Virginia Air Pollution Control Board specifically requested
the Stationary Source Compliance Division (SSCD) to have an evaluation performed
1
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of their existing inspection program and help them to develop a continuing
compliance program within the Commonwealth.
1.1 PURPOSE AND SCOPE
As part of their effort to provide information to State and local agencies
on ways to improve their existing inspection and surveillance programs and to
assist them in their efforts to obtain continuing compliance, SSCD issued a
task to perform this work. The purpose of this task was to evaluate and
field test inspection procedures and analysis methods developed by PEDCo over
the past several years to improve the overall effectiveness of air compliance
inspections. The area selected for evaluation and study was the Commonwealth
of Virginia's Region II Office headquartered in Roanoke.
The purpose of this study was fourfold: 1) to evaluate the inspection
procedures currently used by the Commonwealth of Virginia in the Region II
Office, 2) to train the inspectors in the use of comprehensive inspection
techniques, 3) to develop a modified inspection plan for the Region II area,
and 4) to analyze the effectiveness of the modified inspection plan with
respect to improving continued compliance of the sources located within
Region II.
This study was divided into seven major subtasks: 1) evaluation of the
current inspection procedures, 2) development of targeting criteria for
selecting the sources to be inspected and the level of inspection to be
conducted, 3) training of inspectors in the use of comprehensive inspection
techniques, 4) field training of inspectors to instruct them in the use of
field equipment and the techniques covered in the classroom, 5) development
and implementation of a modified inspection plan for Region II, 6) analysis
of the modified inspection plan, and 7) preparation of a report describing
the study; presenting the methodology, results, and conclusions; and setting
forth specific recommendations regarding the application of the methodology
to other areas in the Commonwealth of Virginia.
1.2 GOALS
The study had three goals. The first was to develop an inspection and
continuing compliance program that could be effectively implemented by the
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Region II staff given their current level of experience and education supple-
mented by the acquisition of additional equipment and the presentation of
classroom and field training instruction. The second was to develop a plan
that would 1) identify previously undetermined violations, 2) reduce excess
emissions resulting from noncompliance, 3) reduce excess emissions resulting
from process and/or control equipment malfunctions, 4) change the attitude of
the sources with respect to continuing compliance, and 5) improve ambient air
quality. The third goal was to develop a plan that could be applied to the
entire Commonwealth of Virginia.
The modified inspection plan or program was to be implemented over a 120-
day period, and the results were to be reviewed and evaluated with respect to
accomplishing the above objectives of the overall continuing compliance plan
for the Region II Office.
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SECTION 2
DESCRIPTION OF THE STUDY
This section describes the study. It includes a description of the
geographic area, a summary of the sources located within the study area and
their associated emissions, the Region II organization and personnel involved
in inspections, the general compliance status of the sources at the beginning
of the study, the inspection procedures currently used in Region II, and a
summary of the types of inspections conducted over the past several years.
2.1 GEOGRAPHIC AREA
The Valley of Virginia (Region II) Office is located in Roanoke, which
includes the following 18 counties: Floyd, Pulaski, Giles, Montgomery,
Roanoke, Craig, Botetourt, Alleghany, Rockbridge, Bath, Augusta, Highland,
Rockingham, Page, Shenandoah, Warren, Clark, and Frederick. The map in
Figure 1 shows the location of the Valley of Virginia Regional Office with
respect to the other Regional Offices in the Commonwealth.
The Great Appalachian Valley, or Valley of Virginia as this region is
sometimes called, is bordered by the Alleghany and Shenandoah Mountains on
the northwest (West Virginia) border, and by the Blue Ridge Mountains on the
southwest (Piedmont Plateau) border. This area is divided up into several
smaller valleys by the Alleghany Mountain Ridge in the western part of the
region and the Massanutten Mountain in the northern part of the region (i.e.,
the upper Shenandoah Valley). Most of these ridges and mountains are between
3000 and 4000 ft (900 to 1200 meters) high.
The climate in Region II is moderate. Virginia's mean temperature is
37°F (3°C) in winter and 74°F (23°C) in summer. Region II's winter tempera-
tures are somewhat lower in winter, however, because of the mountainous topo-
graphy of the area; temperatures occasionally drop to 0 F (-18 C). The area's
average rainfall is approximately 43 inches.
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VIRGINIA
Air Quality Control
Regions and Regional Offices
and Directors
Winchester Branch Office'
45 West Boscawen Street
Winchester. Virginia 22601
(703)662-8071
II
VALLEY OF VIRGINIA
Donald I" Shepherd
Suite A, 5338 Peters Creek Road
Roanoke. Virginia 24019
(703)982-7328
VII
NORTHERN VIRGINIA
JohnC Doherty
The American Building — Suite 130
7535 Little River Turnpike
Annandale, Virginia 22003
(703)941 6346
IV
NORTHEASTERN VIRGINIA "
Ramon P Minx
107-B Butler Road
Fredencksburg, Virginia 22401
(703)899-4165
SOUTHWEST VIRGINIA
Michael D Overstreet
121 Russell Road
Abingdon. Virginia 24210
(703)628-7841
CENTRAL REGION
William W Parks
7701 -03 Timbertake Road
Lynchburg. Virginia 24502
(804)528-6641
STATE CAPITAL
Henry A Moss
2715 A Enterprise Parkway
Richmond, Virginia 23229
(804)281-9305
HAMPTON ROADS
LuctenB McDonald
Pembroke Office Park
Pembroke IV — Suite 409
Virginia Beach. Virginia 23462
(804) 499-6945
Boundaries are official region boundaries L
' Winchester branch, physically in Region II. is administratively under
Region VII. serves Clarke, Frederick, Page. Shenandoah and Warren Counties
and cHy of Winchester
" Eastern Shore counties - Accomack and Northampton - physically in
Region IV, are administered under Region VI,
Figure 1. Virginia Air Quality Control Regions and Regional Offices.
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The Commonwealth of Virginia Air Pollution Control Board has been con-
ducting ambient air monitoring throughout the Commonwealth since January 1968.
The annual geometric mean of total suspended particulate in the Valley of
Virginia is typically 40 to 70 yg/m . The 24-h !
0.02 ppm, and the maximum 1-h CO level is 6 ppm.
Virginia is typically 40 to 70 yg/m . The 24-h SO, levels are on the order of
2.2 SOURCES AND EMISSIONS
The Compliance Data System (CDS) for the Valley of Virginia Regional
Office currently contains 360 sources (Appendix A). Approximately 106 of
these sources are listed as Class A.
Class A sources are divided into three types; Class Al(a) sources are
those stationary sources whose actual emissions after controls are equal to
or exceed 100 tons/yr of any pollutant regulated under the Clean Air Act.
Class Al(p) sources are those stationary sources whose potential emissions
after control would be equal to or exceed 100 tons/yr of any pollutant
regulated under the Act if the facility were operated at designed capacity
(24 hours/day, 365 days/yr). Facilities which are legally restricted to a
specified operating level should be evaluated on that basis. Class A2(p)
sources are those stationary sources whose uncontrolled emissions while operat-
ing at the design capacity are equal to or exceed 100 tons/yr for any regu-
lated pollutant whose actual emissions are less than 100 tons/yr (i.e., uncon-
trolled greater than 100 tons/yr but maximum actual less than 100 tons/yr).
The particulate matter emissions for the Valley of Virginia are approxi-
mately 90,000 tons/yr. The unpaved roads account for about 36 percent of
these emissions and mineral products industry and external fuel combustion
account for another 18 percent and 15 percent, respectively. Table 1 sum-
marizes the particulate matter emissions by major source category.
2.3 ORGANIZATION AND PERSONNEL
In addition to the main office located in Roanoke, the Valley of Virginia
has a branch office located in Winchester. The Winchester Office serves
Clarke, Frederick, Page, Shenandoah, and Warren Counties in addition to the
city of Winchester. Because the Winchester Office is administratively under
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TABLE 1. VALLEY OF VIRGINIA PARTICULATE MATTER EMISSIONS'
Source category
Emissions,
tons/yr
Source category
Emissions,
tons/yr
CO
EXTERNAL COMBUSTION
Residential fuel - area
Anthracite coal
Bituminous coal
Distillate oil
Natural gas
Wood
Electric generation - point
Bituminous coal
Industrial fuel
Anthracite coal - area
- point
Bituminous coal - area
- point
Lignite - point
Residual oil - point
Distillate - point
Natural gas - area
- point
Process gas - area
- point
Coke - point
Wood - point
Liquid petroleum gas - point
Bagasse - point
Other - point
11
172
72
11
,426
65
0
0
868
9,744
0
1,200
97
19
7
0
0
0
85
0
0
0
Commercial-institutional fuel
Anthracite coal - area
- point
Bituminous coal - area
- point
Lignite - point
Residual oil - point
Distillate oil - area
- point
Natural gas - area
- point
Wood - area
- point
Liquid petroleum gas - point
Miscellaneous - point
INTERNAL COMBUSTION
Electric generation
Distillate oil
Natural gas
Diesel fuel
1
0
0
195
0
33
1
15
7
0
0
0
0
0
0
0
0
0
(continued)
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TABLE 1 (continued)
Source category
Emissions,
tons/yr
Source category
Emissions,
tons/yr
i-D
Industrial fuel
Distillate oil
Natural gas
Gasoline
Diesel fuel
Other
Commercial-institutional
Diesel fuel
Other
Engine-testing
Aircraft
Other
Miscellaneous
INDUSTRIAL PROCESS - POINT
Chemical manufacturing
Food/agriculture
Primary metal
Secondary metal
Mineral products
Petroleum storage/transport
Wood products
Organic solvent evaporation
Metal fabrication
Textile manufacturing
Other/not classified
0
0
0
0
0
0
0
0
0
0
1,020
614
0
659
22,069
90
194
138
0
21
419
SOLID WASTE DISPOSAL
Residential - area
On site incineration
Open burning
Commercial-institutional - area
- point
On site incineration - area
- point
Industrial - area
- point
On site incineration - area
- point
Open burning - area
- point
TRANSPORTATION - AREA
Land vehicles
Gasoline
Light vehicles
Light duty trucks
Heavy vehicles
Off highway
Diesel fuel
Heavy vehicles
Off highway
Rail
1,985
37
948
1
57
12
57
12
56
18
47
18
9
0
11,157
3,332
758
26
,256
170
197
(continued)
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TABLE 1 (continued)
Source category
Emissions,
tons/yr
Source category
Emissions,
tons/yr
Aircraft
Civil
Vessels
Gasoline
MISCELLANEOUS - AREA
Forest fires (wild)
Forest managed burning
Structural fires
Slash burning
Frost control
Solvent evaporation loss
Unpaved roads
OVERALL TOTAL: -AREA
-POINT
2
2
0
0
89
1
137
1
0
0
33,154
55,965
36,695
92,660
1975 National Emissions Report, EPA-450/2-78-020, May 1980.
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the direction of Region VII located in Annandale, Virginia, it was not in-
cluded in this study.
The Region II staff consists of a regional director and five engineers
or air pollution control officers, who are responsible for conducting the in-
spections in Region II. Table 2 lists the job titles of individuals respon-
sible for the inspections and their educational level(s) and experience.
TABLE 2. JOB TITLE, EDUCATIONAL LEVEL, AND EXPERIENCE
OF INSPECTORS IN REGION II
Inspector
identification
number
1
2
3
4
5
Position
Regional Air Pollu-
tion Engineer
Air Pollution Con-
trol Officer
Air Pollution Con-
trol Officer
Chemist/Field Rep-
resentative
Assistant Regional
Director
Degree
B.S.,
Engineering
High school
B . S . ,
Environmental
Science/Park
Recreation
B.A.
B.A.
Years
experience
8
11
7
13
11
2.4 SOURCE COMPLIANCE STATUS
Based on the information provided by the Region II staff at the begin-
ning of the study, all Class A sources were determined to be in compliance.
Determinations of compliance were based on one or more of the following:
stack test, visible emission observation, source certification, plant inspec-
tion, and material balance (Appendix B).
In the past, the Region II staff generally conducted on-site inspection
of Class A sources at least once a year. Appendix C is the typical source
inspection report form used to report the information obtained during an
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inspection. This form, along with any narrative discussion, is generally
placed in the inspection file at the completion of each inspection.
2.5 REGION II INSPECTION PROCEDURES PRIOR TO THE STUDY
Prior to the study Region II inspectors were conducting Level I inspec-
tions with a few Level II inspections where plant instrumentation were avail-
able. The inspectors did not measure any operating parameters directly nor did
they conduct any internal inspections of electrostatic precipitators (ESP's) or
fabric filters. The sole indicator of compliance was visible emissions using
EPA Method 9. In some cases the results from performance tests were used
where available. As a result of conducting Level I inspections, the inspectors
were not able to readily detect potential violations of the particulate emis-
sion standards (mass emission limitations) or to detect potential O&M prob-
lems that could affect the overall performance of the control equipment.
Most inspections were initiated as a result of Regional priorities to
determine the compliance status of the major sources in Region II. A few
inspections were also conducted to determine compliance with applicable
new source permit conditions or to investigate a formal complaint received
against a source.
The results of the inspection were typically summarized on an inspection
form (Appendix C) and the results passed on to the Regional Director for his
information and review. In a few cases, more detailed narrative inspection
reports were prepared depending on the results of the inspection.
2.6 SUMMARY OF PAST INSPECTIONS
Prior to the study, the inspection reports were generally limited to
inspection form and possibly one or two pages of narrative. Appendix D con-
tains several examples of inspection reports that were prepared and submitted
prior to the beginning of the study.
As noted, the inspections were generally limited to visible emission
observations and a physical inspection to verify that all required control
equipment had been installed and that it appeared to be operating properly.
As noted above, all sources were determined to be in compliance although some
limited short-term compliance problems were noted in a November 1981 CDS
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Quick Look Report for sources (Appendix B) but these problems were corrected
according to the Region staff and all sources were certified to be in com-
pliance by the Region II Director at the beginning of the study.
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SECTION 3
METHODOLOGY
This section outlines the methodology and technical approach used to
analyze the effectiveness of the modified inspection plan for Region II. The
methodology is composed of four basic elements: 1) classroom instruction,
2) field training, 3) development and implementation of targeting (modified
inspection) plan, and 4) analysis of the results with respect to specified
criteria.
3.1 CLASSROOM
On October 13-15, 1981, PEDCo provided classroom instruction to Region
II staff and others within the Commonwealth of Virginia on the inspection and
operation of air pollution control equipment. Seventeen individuals attended
the classroom training. The informal classroom instruction included discus-
sions on plant inspection techniques, inspection and evaluation of control
equipment, and information and special concerns regarding O&M of industrial
boilers, cement plants, and kraft pulp mills. Appendix E is a copy of the
agenda for the classroom instruction.
The discussions and lectures on comprehensive inspection techniques in-
cluded specific lectures on how to acquire data on such key control equipment
operating parameters as pressure drop, velocity, and secondary current and
voltage. The inspectors were instructed on how to use hand-held inspection
equipment (e.g., tachometers, ampmeters, pressure gauges, oxygen analyzers,
and thermocouples). The inspectors were also instructed on how to establish
and use an inspection filing system and what types of data should be contained
in these files (e.g., flow charts, emission point identification, and inspec-
tion chronology). Procedures were also presented on how to evaluate certain
factors that affect control equipment performance including resistivity,
scrubber throat wear, bag failures, and poor control equipment design.
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Several lectures were also presented on conducting a baseline assessment
and observing performance tests. In particular, the inspectors were instructed
on how to establish a baseline for certain key control equipment operating
parameters for determining the acceptability of a given performance test. The
inspectors were also instructed on how to use the baselining concept to
determine whether a performance test is representative of actual operating
conditions. Finally, procedures were presented on how to analyze O&M records
for evaluating performance trends and the frequency of malfunctions.
The lecture on the inspection of fans and ventilation systems presented
information on the operating theory of the four basic types of fans, rela-
tionship between rpm and static pressure, flow, and horsepower, the use of fan
operating data to determine gas volume through the control equipment, and the
use of hand-held instruments to obtain fan measurements. The limitations of
using fan analysis for flow determinations were also presented. Finally, in-
formation and procedures were presented on how to analyze the operation of a
ventilation system and the types of malfunctions that are frequently encountered.
The lecture on the inspection of mechanical collectors presented infor-
mation on the theory of inertia! collecting devices and effects of certain key
operating parameters (e.g., velocity, diameter, flow, and pressure drop) on
control equipment performance. The lecture also addressed the typical mal-
functions associated with mechanical collectors and the effect of these mal-
functions on mechanical collector performance. Specific mechanical collector
inspection procedures were presented which included procedures on how to con-
duct an internal inspection of a mechanical collector. The inspection pro-
cedures specifically noted which operating parameters should be recorded as
part of the inspection (e.g., pressure drop, flow, and opacity).
The lecture on the inspection of wet scrubbers presented information on
the operating theory of wet scrubbers, typical operating parameters (e.g.,
water flow rate, throat velocity, superficial velocity, and pressure drop)
and their effect on scrubber performance, the major components of a wet
scrubber system (fan, scrubber section, demister, presaturator pump, valves,
and sump), and the typical malfunctions associated with wet scrubbers and
their effect on performance. Inspection procedures for determining scrubber
performance using such operating parameters as pressure drop, flow rate,
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water flow, and gas and water temperature were also presented along with
formulas for calculating throat velocity, liquid-to-gas ratio, and pressure
drop. Finally, procedures were presented for conducting internal inspections
of wet scrubbers.
The lecture on the inspection of ESP's presented information on operating
theory, the major components (plates, wires, shell, hopper, rappers, transformer-
rectifier sets, and controller systems), instrumentation (primary voltage,
primary current, secondary voltage, secondary current, and spark rate), typical
operating parameters and ESP malfunctions and their effect on performance.
Several diagnostic tools were presented that can be used to evaluate ESP per-
formance (air-load and gas-load tests, V-I curves, gas volume calculations,
power level distribution, and effects of resistivity changes on power levels).
Procedures were also presented on how to: 1) reduce ESP data taken during
the inspection, 2) perform the necessary calculations, and 3) conduct internal
inspections of an ESP.
The lecture on the inspection of fabric filters presented information on
the theory of particle collection by filtration, the major components, clean-
ing methods, fabric selection, physical properties of the dust, indicators
of the system performance, and typical malfunctions and their effect on per-
formance. Specific diagnostic and calculation procedures were presented for
evaluating pressure drop, air-to-cloth ratio, and external conditions.
Finally, procedures were presented on how to conduct an internal inspection
of a fabric filter and the items that should be noted during an internal
inspection (e.g., clean side deposits, bag tension, corrosion, and air
inleakage).
The discussion and lecture on the use of opacity as an indicator of con-
trol equipment performance presented information on the theory of opacity and
the limitations of opacity as the sole diagnostic tool. Special discussions
were presented on detached and secondary plumes. Procedures were also pre-
sented on how to develop and evaluate mass versus opacity relationships.
Two special industrial source lectures were provided on cement plants
and kraft pulp mills. These lectures presented information on the process
chemistry, the description of the process, the key parameters for each
process, and the procedures for reducing the acquired inspection data.
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A special lecture was also provided on the safety aspects of inspections.
This lecture presented information on the safety equipment that should be
used, special hazards that may be encountered during an inspection, and con-
fined area entry procedures.
After the discussions and lectures, an examination was given to each
student to evaluate his or her understanding of the material presented during
the classroom instruction. Appendix F contains a copy of the examination.
The highest test score was 87 percent, the lowest was 28 percent, and the
mean was 54.5 percent. The mean score for the Region II staff was 64.7
percent. Five of the six highest scores were made by Region II personnel.
3.2 FIELD TRAINING
After the classroom instruction, PEDCo conducted a series of field
training exercises to instruct the five inspectors in the use of the techniques
and procedures presented during the classroom session. PEDCo also made
arrangements for the Region II Office to purchase the necessary instruments
and equipment to conduct the type of inspections called for during the class-
room session. The equipment included a set of magnehelic gauges, ammeter,-
£fU
thermometer (dial and digital type), hand-held tachometer, and Fyrite^test
kit. PEDCo also provided an equipment check list (Appendix G) to aid the in-
spectors in organizing and preparing for future detailed plant inspections.
The field training involved two sessions. The first session was held
November 15-20, 1981; the second was held May 24-29, 1982. The field training
consisted of three basic elements: 1) brief discussion with plant personnel,
2) inspection of the plant and associated process and control equipment, and
3) post inspection debriefing.
Because the Region II Office staff made the arrangements for the field
training plant visits, plant personnel were generally aware of the training
nature of the inspection as compared with a compliance or enforcement type
inspection. After the initial introductions, PEDCo explained to the plant
personnel the type of measurements that would be acquired and if any addi-
tional sampling locations would be needed. The safety requirements for the
inspection were discussed as was the need to comply with all plant rules
and regulations regarding safety. Information on equipment design and operat-
ing characteristics also was obtained at this time.
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The plant inspection usually centered on one or two pieces of the equip-
ment, especially if the plant had several different processes. Limiting the
inspection to one or two pieces of equipment enabled the field training to
focus on the interrelationship between various design and O&M considerations.
The inspector was instructed on how to obtain and review the data available
from the instrumentation that may be installed at a particular facility
(e.g., pressure drop, fan rpm, ESP power input). The inspector was also
instructed in the use of various hand-held equipment. In particular, the
inspectors were required to take measurements using the Fyrite^and hand-held
tachometer and to use the data obtained to perform various calculations.
As each measurement was taken, a discussion was presented regarding use
of these measurements in evaluating the overall operation and performance of
the source. Throughout the field training, the operating and design principles
of the equipment were reinforced as were the procedures for comparing the de-
sign data with the data obtained during the inspection to enable the inspector
to identify potential problems and associated symptons. Potential O&M problems
also were identified.
In many cases, plant personnel accompanied the Region II inspectors on
the actual inspection. When this occurred, plant personnel were questioned
concerning the kinds of problems they may have encountered and the maintenance
history of the equipment. These questions were asked to give the inspector
an idea of the type of information that should be obtained during an inspec-
tion.
In those cases where the equipment was not in operation or there were no
potential hazards, an internal inspection of the control equipment was con-
ducted. The purpose of the internal inspection was to give the inspector a
firsthand perspective on design considerations as well as operating and main-
tenance problems. Internal inspections (which were generally limited to
fabric filters and multicyclones) were informal and stressed the exchange of
information and the need for a cooperative effort on the part of the Common-
wealth and the source.
Immediately after the actual inspection was conducted, a second meeting
was held with the plant and Commonwealth personnel to discuss the preliminary
findings of the field training inspection. This second meeting provided an
19
-------
opportunity for the Commonwealth and plant personnel to obtain a better
understanding of the need for detailed plant inspections and how the data
from these inspections can be used to correct current problems and avoid future
problems.
At the end of each day of field training, the data obtained during that
day were reduced and sample calculations were performed to illustrate how the
data can be used to relate various design and operating conditions to continu-
ing compliance and to assess the overall performance of the source.
3.3 TARGETING PLAN
Based on a review of the Region II permit and inspection files and a
discussion with the regional staff, PEDCo developed a targeting plan for con-
ducting future inspections in Region II. The targeting plan (i.e., level
of inspection and frequency) was developed to optimize the use of the current
manpower and to ensure continuing compliance of those sources that would have
the greatest impact on air quality and overall emissions in the Region. The
level of inspection recommended is usually different for each individual emis-
sion point at the source, depending on the control equipment, process equip-
ment, and the expected level of maintenance.
3.3.1 Levels of Inspection
Five levels of inspection (0, 1, 2, 3, and 4) were recommended for each
source or process within each source along with the frequency of inspection.
The procedures associated with each level of inspection are explained.
Level 0--
Level 0, the lowest level of inspection, consists of an annual determi-
nation of the continued operation of the source and its annual process
throughput. The purpose of this inspection is to obtain information on those
sources that do not operate emission control equipment. Level 0 inspections
can be used for petroleum storage facilities, paint spray booths, drying
ovens, or uncontrolled degreasing facilities.
Level 1--
Level 1 is considered a screening inspection for identifying violations
of emission standards that can be related to visible emissions. The inspection
20
-------
is usually limited to the evaluation of visible emissions from process vents,
fuel combustion sources, incinerators, and fugitive emission sources. This
type of inspection can be used to enforce opacity standards or particulate
standards when a correlation between opacity and mass emission rates has been
established. This inspection requires a minimum of time and manpower and
places a minimum of regulatory pressure or involvement on the source. This
level of inspection should be limited to sources where there is a minimum
potential for malfunction or excess emissions at abnormal conditions. It
also may be used periodically in connection with more complex inspection levels
to ensure continuing compliance with visible emission requirements. Examples
of sources to which this level of inspection can be applied are gas- and oil-
fired boilers, tenter frames, incinerators, or fugitive emission sources such
as conveyor transfer points and truck loadout facilities.
Level 2--
Level 2 is considered a selective type of inspection in which control
device and process operating conditions are recorded as part of the source
evaluation in addition to visible emission observations. This level of in-
spection, however, does not include the measurement of operating conditions
by the inspector or the completion of a detailed engineering analysis. In a
typical application, the inspector would record such process items as feed
rates, temperatures, raw material compositions, process rates, and such con-
trol equipment performance parameters as water flow rates, water pressure,
static pressure drop, ESP power levels, etc. The inspector would then use
these values to determine any significant change since the last inspection or
any process operations outside normal or permitted conditions. A significant
change in operating conditions could require that the inspector upgrade the
inspection to a Level 3 or that a stack test be conducted to verify compliance.
Levej 3--
Level 3, the most thorough and time consuming inspection, is designed to
provide a detailed engineering analysis of source compliance by use of measured
operating parameters. This inspection requires the measurement of such
control equipment operating parameters as pressure drop, fan static pressure
and current, gas stream temperature, ESP power levels, flue gas conditions,
oxygen level, and water flow rates. The measured data are reduced and used
21
-------
to calculate flue gas volume, superficial velocity, specific collection area,
inlet velocity, air-to-cloth ratio, hood inlet volume and velocity, liquid-
to-gas ratio, throat velocity, etc. Because many of these parameters are
control device and source specific, they must be adjusted to the individual
source being inspected. The two major purposes of this type of inspection
are 1) to determine if the source is operating within accepted design condi-
tions for the specific control device, and 2) to determine if the source is
experiencing O&M problems that result in less than continuing compliance with
the emission standards. The inspection also may include an internal inspection
of the control device. For fabric filters, an internal inspection is re-
quired to determine bag condition or integrity of the baghouse. For scrubbers,
an inspection of the condition of the nozzles is required if the water flow
rate or pressure data indicate the possibility of pluggage. An internal in-
spection of ESP's may be required if power data indicate a problem with ash
buildup or plate alignment. A periodic internal inspection of mechanical
collectors is required where the collection of abrasive dust is likely to
cause abrasion-induced failure. Because this level of inspection requires
the monitoring of equipment conditions and, in some cases, an internal inspec-
tion, the inspector must be sure that all safety requirements are met prior
to entry. In all cases, lockout procedures should be used and applicable
safety equipment employed.
Level 4--
The Level 4 inspection is the preparation of a baseline for the source
through the use of a stack test. This inspection requires that the inspector
monitor all process and control device operating parameters during a stack
test for use during future Level 3 inspections. The inspection ensures that
the stack test results are representative. The Level 4 inspection is typically
applied to sources with ESP's or high-energy wet scrubbers. The inspection
may require documentation of control equipment conditions through the use of
an internal inspection before the stack test or a chemical analysis of process
material or fuel that is being burned (e.g., percent sulfur, percent ash,
heat content, percent moisture).
The purpose of the increasing level of inspection is to concentrate the
resources on those sources that have the greatest potential to exceed the
22
-------
emission limits. Initial results of the Level 3 inspection may indicate that
specific sources are not experiencing deficiencies in performance and therefore
do not warrant a higher level of inspection. In these cases, the frequency
or level of inspection may be adjusted downward consistent with the results
of the Level 3 inspection.
3.3.2 Development of the Targeting Plan
The following is a brief description of the procedures that were used to
develop the targeting plan. The plan considered the type of control equipment
currently installed at each source, the type of source, the source size, the
geographic location, and the operating history of the source.
Control Equipment Type--
Because of the high failure rate for fabric filters installed on high
temperature processes that emit abrasive dust and sulfur trioxide, sources
with fabric filters operating with these conditions were initially targeted
for a Level 3 inspection.
Because ESP's typically experience failures that can reduce performance,
all Class A sources with ESP's were initially targeted for a Level 3 inspection.
In cases where detailed compliance histories were not available for sources
with ESP's, Level 4 inspections were recommended.
The most common failure mechanism in scrubbers is lack of water flow or
reduced energy. Both of these failures generally result in an increase in
opacity from the source. Because of the interference of condensed water vapor
in the plume, accurate opacity observations are difficult to obtain. For this
reason, a more detailed level of inspection is needed. Therefore, all wet
scrubbers (particularly high energy venturi scrubbers) were initially targeted
for a Level 3 inspection.
Type of Source--
Both the abrassiveness and grain loading of dust and the gas stream temp-
erature have an effect on control equipment performance. Shot blasting, coal-
fired boilers, asphalt plants, lime kilns, and cement kilns are high temperature
sources that emit significant amounts of abrasive dust. As a result, these
types of sources were initially targeted for a Level 3 inspection.
23
-------
Source Size--
As the size of the individual source increases both in terms of gas volume
and production, the potential uncontrolled emission rate also increases. As a
result, any major malfunction at these sources can have a potentially signifi-
cant impact on air quality. Therefore, sources with gas volumes in excess
of 10,000 acfm were initially targeted for a Level 3 inspection.
Geographic Location—
Those sources with gas volumes greater than 1000 acfm and located in urban
areas were also targeted for Level 3 inspections because of the potential impact
on the population in the immediate area of the source.
Previous History (Frequency of Malfunction)—
Sources with previous history of malfunctions or improper operation were
initially targeted for a Level 3 inspection because Level 3 inspections should
help to identify the potential causes of the repeated malfunctions.
3.3.3 Refinement of Initial Targeting Plan
As a result of initial screening of the sources using the factors set
forth in Section 3.3.1, approximately 80 percent of the sources were targeted
for a Level 3 inspection. Because of the manpower constraints within Region
II, Level 3 inspections could not be accomplished for all these sources within
a reasonable time frame.
Because of the limited resources, the initial targeting plan was modified.
The modified targeting plan called for a Level 2 inspection three times a year
and a Level 3 once per year. The Level 3 inspection permitted an annual review
of the overall operating procedures of the source, the internal control equipment
condition, type of fuel being burned, gas flow changes, and overall plant
maintenance. The Level 2 inspection premitted the inspector to acquire data
on selected key operating parameters (using plant instruments) that could be
compared to the data obtained during the Level 3 inspection. This modification
to the targeting plan reduced the required number of Level 3 inspections by
65 to 70 percent.
3.3.4 Targeting Recommendations
As noted earlier, a targeting plan was developed for all the Class A
sources located in Region II, based on a review of the inspection and permit
24
-------
files and discussions with each inspector. Figure 2 is an example of the form
that was used to summarize the pertinent information on each Class A source
resulting from the file review and discussion with each inspector.
The targeting plan was presented in tabular form. The table contained
the company or plant name, the applicable permit or Commonwealth registration
number, a list of sources or processes within the plant, the level of in-
spection recommended, and the frequency of inspection (on a yearly basis).
Figure 3 is an example of the tables presented to the Region II staff for
consideration in developing the final modified inspection program.
3.4 ANALYSIS OF RESULTS
In cooperation with the Region II staff and the EPA task manager, PEDCo
developed the following six criteria for evaluating the results of the implemen-
tation of the modified inspection program:
1. Ability of the inspector to incorporate detailed inspections
(Level 3) into routine inspection schedules.
2. The ability to identify violations that were previously un-
detected.
3. Reduction in excess emissions because of correcting noncompliance.
4. Reduction in excess emissions because of correction of process/
control equipment malfunctions.
5. Changes in source attitude.
6. Improvement in ambient air quality.
It should be noted that all the criteria except 1 and 5 (which are ex-
tremely subjective) are quantitative; that is, Criteria 2, 3, 4, and 6 permit
a comparison of the situation before and after implementation of the modified
inspection program to determine if there were any improvements. There are,
however, two limitations to performing a quantitative assessment with these
criteria. The first limitation is that an accurate picture may not exist in
all cases prior to the implementation of the modified inspection program. In
many cases, the amount of excess emissions resulting from equipment malfunctions
or process upsets is not known because the source was determined to be in
compliance and therefore (theoretically) there were no excess emissions. In
25
-------
ro
01
Pane
of
Source name
Source Address
Industrial category:
Process types: 1)
Control equip-
ment types: 1)
Compliance status:
a) Compliance
, 2)
, 2)
b) Noncompliance
,3) ,4)
- , 3) ,4)
5)
5)
Suburban
c) Consent or delayed compliance order
04H problems: yes
no
Complaints/dates: 1)
1)
2)
3)
4)
5)
Permlt(s):
, 2)
Frequency of inspection:
Last inspection (date):
Last stack test (date):
Inspector:
Remarks:
Type:
, 3)
Expiration date(s):
Any special
reasons for
inspection:
Figure 2. Example of form used to summarize information obtained from file
review and discussions with inspectors.
-------
TABLE H-l. TARGETING PLAN FOR REGION II
Company
Adams Construction
Catawba Hospital
General Electric
Koppers
Marathon 011
Mohawk Rubber
General Shale
Old Virginia Brick
No.
20032
20590
20592
20544
20995
20123
20529
Sources
Painting
Boiler (2)
Grit blast
Shot blast
Bake oven
Creosote
Wood boiler
Boiler (2)
Sawing
Boiler (3)
Mixer
Buffer
K1ln
Screening
Crushing
Sand drying
K1ln (2)
Predryer (2)
Grinding
Inspection
Level
3
2
3
2
0
1
3
2
3
2
0
1
3
2
1
2
0
1
3
2
3
2
1
3
2
1
3
2
1
1
3
2
Frequency/yr
1
1
1 (T)a
3
1
1
1
3
1
2
1
2
1
3
1
2
1
2
1
2
1
2
2
1
2
2
1
3
2
1
1
3
(continued)
Figure 3. Example of targeting plan tables.
27
-------
other cases, the source may have been out of compliance, but no estimates
were made regarding the amount of the excess emissions. The second limi-
tation is that ambient air quality can be affected by several factors besides
the amount of emissions. Also, unless the monitoring site is located in
proximity to a source, it is extremely difficult to determine the impact of a
given source on the monitoring site without using air quality dispersion
modeling.
Information used in this evaluation was obtained in two ways. The first
method was to obtain copies of the inspection reports and evaluations or
summaries of these reports during implementation of the modified inspection
plan. These reports contained information on sources, types of problems that
may have been uncovered, and the action taken or planned to correct any
problems or deficiencies.
The second method of obtaining information was to conduct comprehensive
interviews with the five inspectors, four of them in person and one over the
telephone. Figure 4 is a copy of the interview form. The Regional Director
also was interviewed to obtain his input and overall perspective on the
implementation of the modified inspection program and its impact on the
plants located in Region II. The interview focused on how well he thought
his inspectors were implementing the program, the resources that were involved,
how the sources were receiving the results of the modified inspection program,
and whether the cooperation with plants had increased or decreased with the
use of the modified inspection program.
28
-------
Name: Position:
Education: Degree
Institution
Experience:
1. Have you tried to implement Level 3 type inspections?
2. Approximately how many Level 3 inspections have you conducted?
3. Have the technical data obtained during the inspections been useful?
4. Do you believe that more violations of emission standards are determined
as a result of Level 3 inspections (as opposed to Level 1 inspections)?
5. Has the time required for a Level 3 inspection decreased as you have
gained more experience?
6. What is the average time required for a Level 3 inspection?
7. Has the modified inspection technique allowed you to improve your profes-
sional relationship with your sources?
8. Has the program allowed you to improve your professional talents and job
performance?
Figure 4. Inspector Interview Form.
29
-------
9. Have you encountered any problems in applying Level 3 inspections? If
so, what were they?
10. Based on your experience, what has been industry's attitude toward imple-
menting the Level 3 inspections?
11. Based on your experience, have a significant number of O&M-related prob-
lems been identified?
12. What percentage of sources that you have inspected have O&M problems?
13. Have you been able to get O&M problems corrected without issuing a notice
of violation or delayed compliance order?
14. In your own words, how do you feel about the modified inspection program?
Figure 4. Inspector Interview Form, (continued)
30
-------
SECTION 4
RESULTS
This section discusses the targeting or modified inspection plan, the
Region II staff inspections conducted to date, and the results of these
inspections. It also includes discussions regarding the attitude of the
inspectors and industry toward the modified inspection plan instituted in
Region II and toward Region II's overall approach to continuing compliance.
The final discussion in the section concerns the impact of the modified
inspection plan on resources, air quality, and emissions.
The basic approach taken in this study was to provide the necessary
classroom and field training and targeting plan to the Region II staff. They
in turn were to develop their own inspection plan and implement it according
to their own schedule and available resources. Once the modified inspection
plan was developed, PEDCo had minimal contact with the Region II staff. The
contacts were kept to a minimum to enable the Region II staff to implement
what they had learned without additional formal advice and consultation. The
intent of this "hands-off" approach during the implementation phase was to
avoid biasing the results and to simulate typical implementation of a continuing
compliance program given the current constraints, mitigating circumstances,
and limitations faced by many State and local control agencies.
4.1 TARGETING/MODIFIED INSPECTION PLAN
As noted in Section 3.3, a targeting plan was developed for all the
Class A sources (i.e., companies) located in Region II, based on a review of
the inspection and permit files and discussions with each inspector. Appendix
H is the recommended targeting plan supplied to the Region II Director for
his review and comment.
On August 20, 1982, after he had reviewed and evaluated the recommended
plan, the Region II Director developed and issued a revised plan for inspecting
the Class A sources in Region II. This plan was updated and reissued on
31
-------
October 22, 1982 (Table 3). The revised plan uses the five levels of in-
spections described in Section 3.3. The listing of companies is the same as
that contained in the CDS output of point sources. All the sources actually
emit 25 tons/yr or more of particulate matter, sulfur dioxide, carbon monoxide,
nitrogen dioxide, or volatile organic compounds or 5 tons/yr or more of lead;
are affected by NESHAPS; or are listed in Appendix C of 40 CFR 51.
The Commonwealth's targeting plan indicated that they would not conduct
a Level 3 inspection of any source with uncontrolled emissions of less than
25 tons/yr or a Level 2 inspection of any source with uncontrolled emissions
of less than 5 tons/yr at normal operation unless that source emitted lead or
hazardous air pollutants. The Commonwealth's plan also indicated that many
Level 1 inspections would not require contact with the plant unless the
opacity exceeded 20 percent. Level 1 inspections used the procedures set
forth in EPA Method 9.
The plan calls for Level 2 inspections to be conducted annually for all
point sources. Level 1 inspections also will be conducted at the same time,
as appropriate. Any source that lacks the necessary instrumentation to con-
duct a Level 2 inspection should be encouraged to install that instrumentation
or the Region II inspector should conduct a Level 3 inspection.
The Region II inspection plan called for Level 3 inspections of one or
more of the processes or emission points at 60 sources (companies), which are
listed in Table 3. The Region II staff also conducted a Level 3 inspection
at the Virginia Foundry in Roanoke, although this company was not listed.
4.2 INSPECTIONS CONDUCTED
Over the last several months, the Region II staff has been implementing
the modified inspection plan. To date, they have conducted Level 3 inspec-
tions at 36 companies involving more than 60 processes or pieces of control
equipment.
Several factors, however, have influenced the number and levels of
modified inspections that have been conducted thus far by Region II per-
sonnel. The Regional Director has adjusted the number of inspections each
inspector is required to conduct from that called for in the original plan
(Table 3) to account for a number of resource constraints and special circum-
stances associated with the individual inspectors within the Region.
32
-------
TABLE 3. REGION II MODIFIED INSPECTION PLAN
Inspector
identification
number
5
County
Botetourt
Company
Adams Construction
Blue Ridge Stone
James River Limestone
Plant No. 1
James River Limestone
Plant No. 2
James River Limestone
Plant No. 3
Weblite
Webster Brick
Number3
20036
20269
20458
20320
20569
20340
20447
Sources
Plant
Crushers and screens
Baghouse
Handling and storage
Crushers and screens
Baghouses
Handling and storage
Scrubbers
Crushers and screens
Baghouses
Scrubber
Handling and storage
Plant
Sintering machine
Baghouse
Crushers and screens
Handling and storage
Kiln
Crushing and handling
Inspection
Level
2
3
2
2
3
1
2
2
3
1
2
2
2
3
2
1
2
2
2
3
1
2
1
2
1
Frequency
1
1
2
1
1
2
2
1
1
2
2
2
1
1
2
2
1
4
3
1
2
2
4
1
1
CO
CjO
(continued)
-------
TABLE 3 (continued)
Inspector
identification
number
County
Allegheny
and Bath
Company
C&O R.R.
•v
Covington Asphalt
Pantasote
VEPCO
Westvaco
Westvaco
Number
20576
20119
20391
20675
20328
20329
Sources
Plant
Plant
Boilers
Process
Plant
Boilers
Lime kiln
Calciner
Recovery boiler
Slakers
Smelt tanks
Blow tanks
Accumulators
Activation kilns
and scrubbers
Ins
Level
1
2
3
2
1
2
2
1
2
3
1
2
3
1
2
3
1
2
3
2
2
2
1
2
3
pection
Frequency
2
1
1
2
1
1
1
6
3
3
6
3
3
2
2
2
6
3
3
4
4
2
6
5
1
CO
(continued)
-------
TABLE 3 (continued)
Inspector
identification
number
County
Rockbridge
Company
Va. Hot Springs
Adams Construction
C. W. Barger (quarry)
Burlington Industries
General Shale
Georgia Bonded Fiber
Hermetite
Lone Jack Asphalt
Lone Jack Quarry
Number9
20828
20037
20116
20269
20529
20342
20077
20021
20471
Sources
Powdered carbon
Baghouses
Granular carbon
Emission controls
Boilers
Plant
Plant
Coal boiler
Tenter frames and dryers
Kiln
Sand texturizing
Boilers
Boiler
Plant
Crushers and screens
Handling and storage
Baghouse
Inspection
Level f Frequency
1
2
3
1
2
3
1
2
3
2
2
1
2
3
1
2
1
3
1
2
2
2
2
1
2/3
3
2
1
3
2
1
1
1
1
1
1
2
1
1
4
1
1
1
4
1
1
2
2
2
1/1
CO
en
(continued)
-------
TABLE 3 (continued)
Inspector
identification
number
County
3
Botetourt
Montgomery
Company
REA Magnet Wire
Reeves Bros.
Taylor Ramsey
Lone Star Cement
Adams Construction
Adams Construction
Blacksburg/VPI
Incinerator
Cupp Black Top
Radford Limestone
Plant No. 3
Number9
20655
20516
20438
20232
20484
20914
20911
20022
20434
Sources
Plant
Boilers
Curing oven
Boiler
Process
Kilns, raw mill , and
clinker cooler
Miscellaneous sources
Baghouses
Crushers and screens
Handling and storage
Plant
Incinerator
Plant
Crushers and screens
Handling and storage
Inspection
Level
2
1
1
1
2
1
2
3
1
2
1
2
3
1
2
3
2
1
2
3
2
2
3
2
1
Frequency
1
1
1
1
1
2
1
1
1
1
6
3
3
3
2
1
2
2
1
1
1
1
1
2
2
00
en
(continued)
-------
TABLE 3 (continued)
Inspector
identification
number
County
Pulaski
Company
Radford Limestone
Ironto Plant
Sisson & Ryan
Asphalt
Sisson & Ryan
Quarry
Bond Cote
Burlington Industries
Coleman Furniture
Gallimore Paving
Hercules
Hoover Color
Number9
20433
20796
20797
20526
20271
20300
20735
20322
20321
,
Sources
Crushers and screens
Handling and storage
Plant
Crushers and screens
Handling and storage
Plant
Boiler (coal)
Tenter frames
Wood boiler
Cyclones
Finishing
Plant
Plant
Boiler
Process
Inspection
Level
2
1
2
3
2
1
2
1
2
3
1
2
1
2
3
1
2
1
1
2
3
1
2
3
1
2
3
Frequency
2
2
1
1
2
2
1
8
3
1
1
1
4
1
1
4
2
2
2
1
1
2
1
1
2
3
1
to
(continued)
-------
TABLE 3 (continued)
Inspector
identification
number
County
c
Company
Pulaski Furniture
Pulaski
Pulaski Furniture
Dublin
Radford Limestone
Plant No. 1
Radford Limestone
Plant No. 2
Volvo-White Motors
Draper Paving
Exxon
Harris Hardwood
Number
20470
20789
20431
20432
20765
20035
20991
20451
Sources
Boiler
Cyclones
Finishing
Boilers
Woodworking
Finishing
Crushers and screens
Handling and storage
Crushers and screens
Handling and storage
Plant
Plant
Storage tanks
Boilers
i
Cyclones
Ins
Level
1
2
3
1
2
1
1
2
3
2
3
1
2
1
2
1
2
2
3
2
1
2
3
1
2
pection
Frequency
4
1
1
4
2
2
4
1
1
1
1
2
2
2
2
2
1
1
1
1
2
1
1
2
2
to
00
(continued)
-------
TABLE 3 (continued)
Inspector
identification
number
County
Company
Hooker Furniture
Mennel Milling
N&W R.R.
Reliance Universal
Roanoke Electric
Steel
Rockydale Quarry
Singer Furniture
Number3
20523
20711
20468
20469
20131
20456
20212
Sources
Boiler and woodworking
Finishing
Plant
Boilers
Ins
Level
1
2
3
1
1
2
1
2
3
Processes
i
2
3
Plant
Furnaces
Other
Crushers and screens
Baghouses
Handling and storage
Boiler and baghouse
2
1
2
3
1
2
1
2
1
2
3
1
1
2
3
pection
Frequency
2
1
1
2
1
1
8
2
2
4
1
1
1
6
4
2
1
1
2
4
2
3
1
6
2
1
1
i-D
(continued)
-------
TABLE 3 (continued)
Inspector
identification
number
1
County
Company
Virginia Asphalt
i
Walker Foundry
Radford
Lynchburg Foundry
I
2
Augusta
Radford Arsenal
American Safety Razor
Crompton Shenandoah
Number3
20031
20034
20381
20656
20189
20413
Sources
Cyclones
Finishing
Plant
Plant
Baghouses (cupolas)
Baghouses (other)
Scrubbers
Powerhouse No. 1
Powerhouse No. 2
Process and incinerator
Boilers
Process
Boilers
Process
Inspection
Level
1
2
1
2
3
2
1
2
3
1
2
3
1
2
3
1
2
3
1
2
3
1
2
1
2
1
2
Frequency
2
2
2
1
1
2
3
2
1
1
2
1
3
2
1
1
2
1
2
1
1
1
1
1
1
1
1
o
(continued)
-------
TABLE 3 (continued)
Inspector
identification
number
County
Company
DuPont
Luck Stone
i
Moffett Paving
Moore Bros. Asphalt
Reynolds Metals
Stanley Furniture
Staunton Limestone
Number3
20517
20565
20025
20027
20515
20480
20794
Sources
Boilers (coal)
Boilers (oil)
Orion plant
Nylon plant
Crushers and screens
Baghouse
Handling and storage
Plant
Plant
Coal boilers
Oil boilers
Processes
Boilers (wood)
Finishing
Dust system
Crushers and screens
Baghouse
Handling and storage
Inspection
Level
1
2
3
1
1
1
2
2
2
3
1
2
3
2
3
1
2
3
1
1
2
1
2
3
1
1
2
2
2
3
1
Frequency
2
1
1
1
3
1
1
2
1
1
2
1
1
1
1
1
1
1
1
1
1
2
1
1
2
1
1
2
1
1
2
(continued)
-------
TABLE 3 (continued)
Inspector
identification
number
County
i
i
Rockingham
i
i
1
Company
Va. Metal crafters
M. A. Layman
(Valley Paving)
Belmont Trap Rock
Wayn-Tex
Dept. of Corrections
Blakemore Construc-
tion
Elkton Limestone
Ethan Allen
Frazier Quarry
Number3
20518
20026
20206
20337
20412
20039
20018
20548
20005
Sources
Baghouse
Plant
Crushers and screens
Handling and storage
Boilers
Process
Boilers
Plant
Crushers and screens
Baghouses
Handling and storage
Boiler
Dust system
Finishing
Crushers and screens
Baghouse
Handling and storage
Ins
Level
2
3
2
3
2
1
1
2
1
2
3
2
3
2
2
3
1
1
2
3
1
2
1
2
2
3
1
pection
Frequency
1
1
1
1
2
2
1
1
1
1
1
1
1
2
1
1
2
1
1
1
1
1
2
2
1
1
2
(continued)
-------
TABLE 3 (continued)
Inspector
identification
number
County
Company
Frazier Quarry
A. N. Johnston
M. A. Layman
JMU
Merck & Co.
Number9
20919
20972
20038
20117
20524
| i
C. S. Mundy
Quality Feeds
ROCCO
Rockingham Milling
20208
20771
20087
20513
Sources
Crushers and screens
Baghouse
Handling and storage
Plant
Plant
Boilers
Coal boilers
Incinerators
Processes
Crushers and screens
Baghouse
Handling and storage
Boilers
Process
Boilers
Process
Boiler
Process
Inspection
Level
2
2
3
1
2
3
2
3
2
1
2
3
1
2
3
2
2
2
3
1
1
2
1
2
1
2
Frequency
2
1
1
2
1
1
1
1
1
1
1
1
1
1
1
2
2
1
1
2
1
1
1
2
1
1
CO
(continued)
-------
TABLE 3 (continued)
Inspector
identification
number
4
County
3iles,
Blacksburg,
and
Christians-
Durg
Company
Rockingham Poultry
Wampler Foods
West Sand & Gravel
Adams Construction
APCO
Celanese
National Gypsum
(Gold Bond)
Number
20786
20553
20982
20033
20460
20304
20225
Sources
Boilers
Process
Boilers
Process
Crushers and screens
Handling and storage
Plant
Plant
Boilers (coal)
Gas/oil boiler
Scrubbers
Baghouses
Carbon adsorbers
Kilns
Other processes,
Handling and storage
Ins
Level
1
2
1
2
2
1
2
3
1
2
3
1
2
3
1
1
2
1
2
1
2
3
1
2
3
pection
Frequency
1
1
1
1
2
2
1
1
6
3
3
2
2
2
1
1
1
1
2
6
4
2
3
2
1
(continued)
-------
TABLE 3 (continued)
Inspector
identification
number
County
Company
Virginia Lime
VPI & SU
Wolverine
Number9
20341
20124
20763
Sources
Kilns
Other processes
Handling and storage
Boiler No. 6 and No. 7
Gas/oil boilers
Boiler
Incinerator
Ins
Level
1
2
3
1
2
1
2
3
1
1
2
section
Frequency
3
2
1
3
3
4
1
1
1
1
1
01
Commonwealth Registration Number.
Responsibility for these sources may be delegated to Bob Saunders.
cCity of Roanoke.
-------
The distribution of inspections was adjusted according to the number and
types of sources operating at each facility. Currently, 95 inspections are
being conducted annually by the 5 inspectors in Region II (2 by Inspector 1,
30 by Inspector 2, 32 by Inspector 3, 7 by Inspector 4, and 24 by Inspector
5).
4.2.1 Summary of Inspections
Over the period of the study, several facilities in Region II have
either ceased operation or have severely restricted their operating hours as
a result of the economic recession. This has resulted in a day-to-day adjust-
ment in the number and frequency of scheduled inspections. Although the
overall impact of economic conditions on the pilot study cannot be assessed
at this time, the initial impact has been a reduction in the number of in-
spections made during the initial study period. Although the original time
frame for completing the study was extended to increase the number of inspec-
tions, a large number of facilities have yet to be inspected under the modi-
fied inspection plan.
To date, approximately 68 of the processes or emission points have been
inspected (i.e., about 37% of the companies). Table 4 summarizes the results
of these inspections. Because many of the sources were promised anonymity in
terms of identifying problems for the purposes the pilot study report, the
sources are listed only by an arbitrarily assigned identification code.
4.2.2 Analysis of Inspections
The Regional Director required the inspectors to document the results of
each Level 3 inspection conducted during the study period. The documentation
was in the form of a narrative report that identified the sources inspected
and any deficiencies noted in each operation and its associated control
equipment. Appendix I is an example of the inspection reports that have been
prepared as a result of implementing the modified inspection program. PEDCo
reviewed these inspection reports and interviewed each inspector concerning
details of the inspection. Over the study period no Level 4 inspections were
conducted, but several are expected to take place as a result of information
obtained during Level 3 inspections.
46
-------
TABLE 4. RESULTS OF VIRGINIA PILOT STUDY - LEVEL 3 INSPECTIONS
Source
ID
A
B
C
D
E
F
G
Source
type
Crushing/
screening
Crushing/
screening
Control
device
FF
FF
I
Handling/ WS
storage
Sintering
Asphalt
Recovery
boiler
Lime kiln
Power
boiler
Carbon
Boiler
Kilns
1-4
Raw mill
Clinker
cooler
FF
WS
ESP
VS
ESP
VS
MC
ESP
ESP
FF
Problems
identifiable
by inspec-
tion level
1
3
X
X
X
P
x
i
xd
H
xd
H
xa
p
xe
p
xe
X
Compliance
In
X
X
X
X
X
X
X
X
Out
xd'e
d
X
d.e
X
d,e
x '
P
x
Problem
Unknown
O&M
x
x
X
X
X
X
Action taken
Corrected
with agreement
x
x
x
f
X
n
X
f
X
NOVb
COC
Other
x
45,
—I
(continued)
-------
TABLE 4 (continued)
Source
ID
H
I
J
K
L
M
Source
type
Kiln 5
Silo
Fringe
cl inker
Finish
mills
Asphalt
Boiler
Wood
boiler
Asphalt
Mill no. 1
Mill no. 2
Mill no. 3
Calciner
Boiler
Woodwork-
ing
Control
device
ESP
FF
_
FF
FF
MC
MC
VS
FF
FF
FF
FF
MC
FF
Problems
identifiable
by inspec-
tion level
1
xd
xd
d
X
3
X
X
X
X
X
X
X
X
Compliance
In
X
X
f
X
X
X
X
Out
e
X
xe
xd
d
X
xd
xd'e
Problem
Unknown
X
O&M
X
X
X
X
X
X
X
X
X
Action taken
Corrected
with agreement
X
X
X
X
X
X
X
X
NOVb
COC
Other
Install
silos
Install
FF
CO
(continued)
-------
TABLE 4 (continued)
Source
ID
N
0
P
Q
R
S
Source
type
Boiler
Asphalt
Boiler
Shotblast
Foundry
Steel -
2, 3
EAF no.
4
Quarry -
Fines mill
New fines
mill
Boiler
Woodwork-
ing
Control
device
MC
FF
MC
FF
WS
FF
MC
FF
FF
FF
MC
FF
Problems
identifiable
by inspec-
tion level
1
xd
xd
xd
xd
3
X
X
xe
xe
X
X
X
X
X
X
Compliance
In
X
X
X
X
X
Out
xd
xe
xd'e
x"'e
xe
xd
Problem
Unknown
O&M
X
X
X
X
X
X
X
X
X
X
Action taken
Corrected
with agreement
X
xf
X
X
h
X
X
X
X
X
NOVb
X
X
COC
Other
ESP to
be in-
stalled
in 1984
Replace
with
new FF
Replace
with FF
VD
(continued)
-------
TABLE 4 (continued)
Source
ID
T
U
Source
type
Asphalt
Medium
cast
facility
EAF
Cupola
Shakeout
Sand
shakeout
Shot
handling
j
i
V
Shot
blasting
Sand
reclaim
Boiler
no. 1
Boiler
no. 2
Control
device
WS
WS
FF
FF
FF
FF
FF
FF
FF
MC
ESP
Problems
identifiable
by inspec-
tion level
1
xd
3
X
X
X
X
X
X
X
X
X
X
Compliance
In
X
X
X
X
X
X
X
X
X
Out
xd
xe
Problem
Unknown
O&M
X
X
X
X
X
X
X
X
X
X
Action taken
Corrected
with agreement
X
X
X
X
X
NOVb
i
V
X
1
1
X
X
X
COC
Other
Replace
with
new FF
Replace
with
new FF
Replace
with
r r~
new FF
Replace
with
new FF
Ul
o
(continued)
-------
TABLE 4 (continued)
Source
ID
W
X
Y
Z
AA
BB
CC
DD
EE
Source
type
Boiler
Crushing
Asphalt
Boilers
Woodwork-
ing
Asphalt
Institu-
tional
boiler
Boiler
Woodwork-
ing
Boilers
Power
generation
boiler no.
5
Control
device
FF
FF
FF
MC
FF
FF
MC
MC
FF
MC
ESP
Problems
identifiable
by inspec-
tion level
1
xd
xd
3
xe
X
X
X
xe
Compliance
In
X
X
X
X
X
X
X
X
X
Out
xd'e
xd'e
Problem
Unknown
O&M
X
X
X
X
X
Action taken
Corrected
with agreement
X
X
X
X
X
NOVb
COC
Other
Poor
opera-
tion 0
propos
ing FF
Reduce
operat
ing
rates
(continued)
-------
TABLE 4 (continued)
Source
ID
Source
type
Boiler
no. 6
FF j Boiler
GG
Kiln
Control
device
ESP
ESP
FF
I
Kiln
1
HH
II
JJ
Gravel
bed
filter
Problems
identifiable
by inspec-
tion level
1
xd
Kiln WS
Institu-
tional
boiler
Cupola
Brass
smelter
MC
1
FF
FF
xd
3
X
xe
X
X
xe
X
Compliance
In
X
X
X
X
Out
xd'e
xe
x«-e
xe
Problem
Unknown
O&M
X
X
X
X
X
Action taken
Corrected
with agreement
X
X
X
X
NOVb
COC
X
Other
IN3
3FF = fabric filter.
ESP = electrostatic precipitator.
WS = wet scrubber.
VS = Venturi scrubber.
MC = multicyclone.
DNOV = Notice of Violation.
'CO - Compliance Order.
JVE limit.
Particulate emission limit.
Part corrected, part being corrected.
^In process of being corrected.
Unknown - obtaining additional information,
= Electric Arc Furnace.
-------
In summary, 36 companies (68 individual processes or emission points)
received Level 3 inspections. Under the modified targeting plan, many
sources were inspected more than once during the study period. To date,
Level 3 inspections have been conducted at approximately 60 percent of the
companies for which such inspections were required.
An initial review of the Region II files, registration list, CDS output,
and inspector interviews conducted at the beginning of the study indicated
that no sources were in violation of regulations limiting particulate or
visible emissions. One source, however, was identified as having been
granted a variance from the Air Pollution Control Board to operate at an
opacity of 50 percent as long as it met the particulate emission standard.
Granting of this variance was based on the information submitted by the
company that it was not technically or economically feasible for them to
comply with the opacity standard of 20 percent.
Prior to the initiation of the study, Region II was using a combination
of Level 1 and Level 2 inspection techniques to determine compliance. The
inspectors made no measurements and no internal inspections were conducted on
control equipment to certify compliance or operating conditions.
Under the modified inspection program, the inspector uses a number of
parameters extending beyond visible emissions to determine compliance. A
significant increase in particulate emissions can often occur as a result of
equipment malfunction without an accompanying increase in observed opacity.
Using engineering judgment, equipment design data, and equipment performance
measurements, the inspector was able to determine compliance with the appli-
cable particulate matter emission limitation.
As a result of the more detailed inspection of the control device, the
inspector was also able to determine the cause of the noncompliance condition.
If a problem was identified, a judgment was made concerning the cause of the
problem (i.e., O&M- or design-related, Table 4).
In many cases, problems were identified that were not serious enough to
result in noncompliance but which generated emission levels above those con-
sidered achievable according to the design capabilities of the collector.
The 68 Level 3 inspections of individual processes or emission units
identified 25 sources (37%) as being out of compliance with either visible
or particulate emission standards (28% visible emission standard, 32%
53
-------
paniculate emission standard, 40% both). Of the total number of processes
or emission units inspected, 46 (67%) were identified as having O&M-related
problems (Table 5).
TABLE 5. SUMMARY OF INSPECTIONS USING LEVEL 3 METHODS
Plants where Level 3 inspections were required
Plants where Level 3 inspections were conducted
Sources where Level 3 inspections were required
Sources where Level 3 inspections were conducted
Plants out of compliance
Sources out of compliance
Visible standard
Particulate standard
Both
Sources with O&M problems
Number
61
36
96
68
17
25
7
8
10
46
Percent
_
59a
-
70a
47b
36b
28b
32b
40b
67b
Percent of total called for in modified inspection plan.
Percent inspected.
It should be pointed out that of the 25 sources for which compliance
problems were identified, only 12 would have been identified as a result of
a Level 1 inspection (i.e., type of inspection commonly conducted prior to
the study). It should also be noted that only the VE portion of the problem
would have been identified as a result of a Level 1 inspection. In addition,
of the 46 sources for which O&M-related problems were identified, none of
the problems would have been identified through the use of a Level 1 inspec-
tion.
The policy of the Air Pollution Control Board has been to enforce air
regulations in a manner that would encourage voluntary compliance with the
applicable standards. The Board does have the legal and regulatory authority
to impose penalities and issue orders to secure compliance with standards
when voluntary compliance is not effective.
In keeping with the policy of voluntary compliance, Region II has
developed a procedure for addressing deficiencies in control equipment
54
-------
performance discovered during Level 3 inspections. When a deficiency is
determined, the source is advised of the problem and requested to take cor-
rective action. Depending on the time requirements, one of the following
actions generally occurs:
o If proposed corrections can be completed within 30 days, an in-
formal agreement is made between the source and the Agency. The
source is reinspected after 30 days to confirm that the corrective
action has been taken.
o If the proposed correction will take between 30 and 90 days, the
Agency issues a notice of violation and enters into a formal con-
sent agreement.
o If the proposed corrective action will take longer than 90 days,
a Board action is required, which could include a compliance
order (CO).
Based on the above criteria, 45 O&M problems have been handled by informal
agreement. Most of the corrections are neither capital-intensive nor require
extensive downtime. In most cases, the source is able to complete the action
during scheduled maintenance periods.
Two processes or emission units at source Q have required the issuance
of a formal Notice of Violation (NOV) to correct operational problems that
have resulted in noncompliance with emission standards.
One source was identified as having visible and particulate violations
prior to the study and was issued a Board order during the study period.
Data obtained during Level 3 inspections have been used to support specific
corrective actions pursuant to this order.
Under Virginia regulations, an excess emission period must be judged as
"unpreventable and sudden" to qualify as a malfunction. Based on the inspec-
tors' reports, types of problems identified, and interviews with the inspec-
tors, the problems found during Level 3 inspections would not qualify as a
malfunction and are therefore classified as excess emissions that should be
reduced or prevented.
4.3 ATTITUDE OF THE INSPECTOR
The attitude of the inspector is critical to the implementation of a
modified inspection plan that stresses continuing compliance. Although the
inspector may have the educational background and experience to implement the
55
-------
modified inspection plan, if he does not believe in the goals and objectives
of the plan, the implementation will not be effective. Therefore, one impor-
tant criterion in evaluating the effectiveness of the modified inspection
plan in Region II is inspector attitude.
4.3.1 Response to Interviews
As noted in Section 3, each of the inspectors was asked a series of 14
questions. Table 6 summarizes the responses to questions 1 through 13 which
lend themselves to short yes/no responses. The responses to question 14--in
your own words, how do you feel about the modified inspection program?—are
discussed in Section 4.3.2.
4.3.2 Analysis of Interviews
The following is an analysis of the interviews with the inspectors with
regard to their acceptance of the comprehensive inspections, their personal
advancement, and their relationship with the plants.
Acceptance of the Comprehensive Inspections--
Initially, some of the inspectors expressed general skepticism concerning
the benefits of the modified inspection program. The areas of doubt centered
around the potential for noncompliance and whether the modified inspection
techniques would identify additional problems.
Over the course of the study each inspector has attempted to use the
inspection equipment and to give the program a fair and unbiased trial. Two
inspectors have made extensive use of the inspection equipment and techniques
and have developed methods and criteria exceeding that specified in the
training. Two inspectors have used portions of the training and equipment to
support Level 2 inspection conclusions, but have not attempted to apply all
methods in each case. One inspector still remains cautious concerning the
use of these techniques but has had limited exposure to the Level 3
techniques.
Three of the inspectors expressed a concern regarding the safety of in-
ternal equipment inspections. This concern is valid, and all inspectors have
followed established guidelines with respect to confined area entry. The
inspectors have requested that additional instruction and information be
provided regarding internal inspectors.
56
-------
TABLE 6. SUMMARY OF INSPECTOR RESPONSES
Inspector
1
2
3
4
5
Q
la
Yes
Yes
Yes
Yes
Yes
2b
4
2
13n
6
3
3C
Yes
Yes
Yes
Defi-
nitely
Yes
4d
Yes
Yes/No
Yes
No,
but
saved
sources
money
No
5e
No
Yes
Yes
Yes
No
6f
4 h
2 h
4 h
2 h
2-3is h
uestion number
?9
Yes
Yes
Yes
Yes
Yes
8h
Yes
Yes
Yes
Yes
Yes
91
Yes
None
No
Yes
2
sources
No
10J
Favorable
Generally
receptive
Generally
receptive
Generally
receptive
Cautious
I1k
Yes
Yes
Yes
Yes
No
121
75%
7-8%
50-
75%
80-
90%
0
13m
Yes
Yes
Yes
Yes
N/A°
in
Have you tried to implement Level 3 type inspections?
Approximately how many Level 3 inspections have you conducted?
Have the technical data obtained during the inspections been useful?
Do you believe that more violations of emission standards are determined as a result of Level 3
inspections (as opposed to Level 1 inspections)?
Has the time required for a Level 3 inspection decreased as you have gained more experience?
What is the average time required for a Level 3 inspection?
the modified inspection technique allowed you to improve your professional relationship with your
sources?
Has the program allowed you to improve your professional talents and job performance?
-------
Have you encountered any problems in applying Level 3 inspections? If so, what were they?
JBased on your experience, what has been industry's attitude toward implementing the Level 3 inspections?
Based on your experience, have a significant number of O&M-related problems been identified?
What percentage of sources that you have inspected have O&M problems?
mHave you been able to get O&M problems corrected without issuing a notice of violation or delayed
compliance order?
"Thirteen sources, 32 individual Level 3 inspections.
°Not applicable; has not discovered any O&M problems.
en
OS
-------
Based on the inspectors' comments during the interviews and on written
statements in their inspection reports, the more comprehensive inspection
methods have been accepted and incorporated into their inspection routine.
A sample of comments received are:
o "This method of inspection has produced excellent results "
o "I feel that this equipment has greatly improved our ability to
identify existing and potential problems. I have also found that
most sources are very receptive to our new inspection procedures "
o "I believe the sources have more respect for our program because we
are now trained to assist in finding solutions to problems "
The Regional Director has indicated that the inspectors can enter faci-
lities with the confidence and expertise necessary to understand plant pro-
cesses and control equipment. As a result of this study, each inspector has
a better understanding of the basic functions of the control devices and
operating parameters. In general, the inspectors' attitude toward inspections
and industry's attitude toward the inspector have improved.
Personnel Advancement--
Each inspector agreed that the comprehensive inspection methods, access
to technical information, and training have increased his personal knowledge
and technical abilities. The ability to extend the scope of the inspection
by using technical information has increased the inspector's awareness of his
professional status and abilities. This is exemplified in his overall job
performance and his general self image as a professional. As the inspectors
conduct more inspections and learn from the data obtained, their ability to
analyze problems will increase, along with their confidence to conduct the
comprehensive inspections and analyses critical to continuing compliance.
Industry Respect--
Based on the inspector interviews and comments from industry in the
area, the inspectors have gained considerable respect in the eyes of plant
personnel. Although the inspector has always been viewed as qualified and
fair, industry has gained a new respect for the inspector as a technically
qualified person capable of discussing, understanding, and evaluating the
operation of air pollution control equipment.
59
-------
4.4 ATTITUDE OF INDUSTRY CONCERNING COMPREHENSIVE INSPECTIONS
The attitude of industry toward the change in inspection procedures is
difficult to evaluate without a specific plant-by-plant survey. A few plants,
however, have made unsolicited favorable comments concerning the inspection
activities. One letter stated, "We subscribe to the Air Pollution Control
Board's program and look forward to continuing good relations." Copies of
several letters that have been received from the industry in Region II regard-
ing the implementation of the modified inspection program are included in
Appendix J.
Each inspector was questioned concerning the plant's attitude with re-
spect to the modified inspection program. One inspector indicated that in-
dustry was cautious and concerned about the potential for increased cost.
Two inspectors indicated that most sources welcome the new inspection ap- ,
•i
proach because of the knowledge they gain from the inspections.
It is the opinion of the Regional Director that about 50 percent of the
plants see substantial benefits from the new more comprehensive inspections
because of the measurements and analyses conducted by the inspectors. Also,
finding the cause of failures has been extremely helpful to plant managers and
operators in planning corrective action. In many cases, maintenance personnel
are now assigned to the inspector so they can obtain helpful information dur-
ing the course of the inspection.
Many plants do not consider this Agency/plant relationship a consultant/
client relationship, but rather an added resource through which the plant can
determine the proper corrective action to ensure continuing compliance.
After the problems have been identified, the plant will generally seek the
services of a consultant or engineering firm to plan and complete the necessary
changes, if they are extensive.
The Regional Director expressed the viewpoint of most of the sources as •-
follows "...it has also improved our relations with most industry, since they
now see us more as partners in the continuing effort to ensure that their
costly investments in pollution controls actually produce cleaner air..."
Only one source has indicated any open resistance to the changes in in-
spection procedures. This attitude appears primarily to be the result of the
increased attention to certain sources that could result in extensive and
costly modifications. The source is currently operating under a Board variance
60
-------
allowing an opacity limit of 50 percent. The increased inspection data have
raised questions concerning the ability of the plant to comply with a lower
opacity limit.
The Regional Director stated, "With one exception, the industries where
we have used the advanced inspection techniques have been receptive. Typically,
the initial reaction to the procedure is one of skepticism because they
believe that their control equipment is operating as well as can be expected.
Their next reaction is usually shock or embarrassment when developing problems
are identified. Finally, they will express their gratitude for being shown
the problem before it becomes a major concern; at this point most sources
agree to repair the problem and/or improve their maintenance programs."
Appendix K is a brief summary prepared by the Region II Director on how
the inspection procedures have changes for each source as a result of this
study. In addition to this brief summary, the Regional Director and the
Director of the Division of Compliance have prepared two letters regarding
the overall results of the pilot study (Appendix L).
4.5 AGENCY APPROACH TO CONTINUING COMPLIANCE
The Commonwealth of Virginia Air Pollution Control Board has made a com-
mitment to a program of continuing compliance for the sources within its
jurisdiction. Through the use of more comprehensive inspections and increased
emphasis on O&M, excess emission periods are identified and corrective action
taken. Because many problems may be corrected in a short period of time, a
nonpunitive approach to solving these problems has been taken. In the words
of the Director of the Division of Compliance, "By emphasizing the cooperative,
nonpunitive approach, we have minimized any sense by industry that they are
being unduly harassed."
If the problems are extensive or the source is unwilling to make voluntary
corrections, the Board may, at its discretion use legal or administrative
methods to assure compliance. These methods may include NOV's, CO's, variances,
and civil or criminal penalties.
4.6 RESOURCES REQUIRED TO IMPLEMENT COMPREHENSIVE INSPECTIONS
The cost of equipping an inspector with the instruments necessary to
conduct Level 3 inspections is approximately $500. In Region II, two complete
61
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sets of inspection equipment were used. Because Level 3 inspections are
targeted and preplanned, this equipment can be reserved and made available
for each scheduled inspection.
To ensure that the inspections were conducted efficiently and to mini-
mize the time required by industrial personnel, the Regional Director placed
a 4-hour time limit on Level 3 source inspections. According to the inspec-
tors, Level 3 inspections have taken from 2 to 4 hours, depending on complexity
of the source and the number of processes or control devices involved.
The extra time required for Level 3 inspections made it necessary to
reduce somewhat the total number of inspections typically conducted. With
the reduction in the number of inspections from 95 to 60, greater emphasis
was placed on those sources causing the most serious problems and those with
the greatest potential to cause problems.
Many of the inspectors have noted that the initial Level 3 inspection at
a source requires more time than subsequent followup inspections because they
must locate the sampling ports and access points, and discuss the inspection
with plant personnel. In subsequent inspections, both the inspector and
plant maintenance personnel are aware of the measurements that must be made
and proper locations for these measurements. Also, data requirements are
greater during the initial Level 3 inspection than during subsequent inspec-
tions. Any design data that are not available from registration or permit
files are usually obtained during the initial Level 3 inspection (i.e., the
inspector must prepare a baseline for the major operating parameters). These
data generally include fan model and manufacturer, fan rpm, fabric filter
size, number of bags, cloth area, venturi scrubber throat area, etc. One in-
spector indicated that the time required for a typical Level 3 inspection was
reduced by 50 percent in subsequent inspections.
Adjustments can be made in the amount of data and the time required to
conduct a Level 3 inspection, depending on site-specific factors. As more
Level 3 inspections are conducted, site-specific inspection forms can be
developed that will further reduce data and time requirements.
4.7 IMPACT ON AIR QUALITY
The primary purpose of a continuing compliance program is to ensure that
the NAAQS are attained and maintained. Therefore, the air quality levels
62
-------
within an area should be an indication of how well the continuing compliance
program is working within that area. Several factors can affect air quality,
however, and make it difficult to evaluate the impact of a continuing com-
pliance program on air quality. One such factor is the meteorological condi-
tions of the area. The amount of rainfall, the average windspeed, the number
of days with inversions, etc., all affect the measured total suspended particu-
late (TSP) levels. It is often difficult to determine without extensive
analyses, whether the air quality has actually improved in a given year or
meteorological conditions have tended to make the concentrations lower.
Another factor is the location of the monitoring sites with respect to
the major sources within an area. In some cases, the monitoring sites are
selected to represent an areawide air quality picture; whereas in other cases,
they are located near major point sources to obtain information on the air
quality impact of the source in question. If only areawide monitors are
available, detailed dispersion modeling is necessary to determine which
sources may have an impact on the monitors and to what extent. Of course,
impacts vary with the meteorological conditions being simulated in the air
quality dispersion modeling analysis.
In general, because most of the monitors in Region II are areawide moni-
tors, it is very difficult to assess the impact of reducing malfunctions and
excess emissions without the use of detailed dispersion modeling, which was
beyond the scope of this study. Therefore, the impact of the modified inspec-
tion program on air quality could not be evaluated. The air quality in
Region II has improved somewhat over the last several quarters; however,
without a detailed statistical evaluation of the air quality levels for the
last couple of years (which again was beyond the scope of this effort) it is
difficult to determine if this trend is due to the implementation of the
modified inspection program.
4.8 IMPACT ON EMISSIONS
The inspectors obtained little information on the amount of excess
emissions that may have been avoided because the modified inspection program
was implemented. Each of the inspectors believed that previously unidentified
63
-------
excess emissions had been discovered and that, almost all of the conditions
causing these excess emissions had been corrected. Thus, in a qualitative
sense, the amount and frequency of excess emissions have been reduced as a
result of implementing the modified inspection program.
Appendix M of this report, however, does present two case histories of
plants where the modified inspection plan provided for some real improvements
in the overall operation of the source.
64
-------
SECTION 5
CONCLUSIONS AND RECOMMENDATIONS
5.1 CONCLUSIONS
The following conclusions are based on the limited number of inspections
that have taken place in the short time period the modified inspection program
has been in use.
1. Forty-six O&M-related problems have been identified to date by
using Level 3 inspection techniques. These problems would not
have been identified using the Level 1 inspection techniques.
2. Most O&M problems were corrected without issuing NOV's and CO's
because the sources sensed a new cooperative spirit on the part
of the inspector to help identify the potential cause of the
O&M problem.
3. Most O&M problems were corrected within a 30-day period because
it was economically feasible for the source to correct the problem.
4. Comprehensive inspections were generally welcomed by certain sources,
however, other sources were more cautious and reserved.
5. The inspectors have improved their technical abilities and profes-
sional status with industry through the implementation of compre-
hensive inspection techniques.
6. Inspectors were able to incorporate comprehensive inspections into
their inspection schedules with only minor adjustments.
7. The data collected to date are insufficient for determining the
impact of comprehensive inspections on emissions or ambient air
quality. Based on the number of O&M and compliance problems cor-
rected and the average reduction in visible emissions, a positive
improvement has occurred.
8. The Region II Office was able to implement the modified inspection
plan using their current resources with little outside assistance
once they had received the classroom and field training instruction
and had an opportunity to test the procedures on their own.
Because all of the inspections have not been completed and all sources have
not been revisited, these should only be considered interim conclusions.
65
-------
5.2 RECOMMENDATIONS
It is believed that the initial problems uncovered by the inspectors will
be corrected and that the affected equipment will be operated properly for an
undefined period of time. Because repeat inspections have not yet been made,
it is not possible to assess the long-term impact of the modified inspection
program. Malfunction of the equipment could continue, or new problems could
occur. Only with a longer tracking period (2 to 5 years) can the long-term
impact of the comprehensive program be determined. Based on the comments of
the Regional Director and the Director of the Division of Compliance, the
Commonwealth will continue to conduct more comprehensive inspections. With
time, however, these inspections will change in scope, applicability, and
frequency as problems are corrected. Based on the results of the study to
date, the following recommendations are made:
1. The study should be extended for a 2-year period, during which time
the inspection activities should be tracked.
2. The inspector should be required to complete an inspection summary
card on each inspection (Level 1, 2, 3, etc.). This card should in-
clude, as a minimum, time on site, type of control device, measure-
ments conducted, compliance status, nature of equipment deficiencies,
and action taken. This form must be designed so that the preliminary
information on each source can be entered prior to the scheduled
inspection and the form can be completed in 10 minutes or less.
The information on this card can be used to perform a more quantita-
tive assessment of the impact of the modified inspection program.
3. One or two source-oriented ambient particulate monitors should be
established to determine the effects of malfunctions and O&M
problems on ambient air quality.
4. Additional safety manuals and instruction should be provided to
the inspectors to address their safety concerns.
5. At the end of a 2-year period, a comprehensive industry survey
should be conducted to determine their reaction to the program.
6. Specific detailed control equipment histories should be developed
for several sources and these histories updated to determine the
long-term effects of the modified inspection program.
66
-------
APPENDIX A
CDS OUTPUT FOR THE VALLEY OF VIRGINIA
A-l
-------
QUICK LOOK REPORT
05/20/81
COHPL1ANCE DATA SYSTEM
SPECIAL VIRGINIA REGION REPORT
STATE REG. NO.
SOURCE NAME
CNTY SIC SIC CODE DESCRIPTION
20000 COMMENT
20001
20004
20005
20018
20020
20021
20022
20023
20024
20025
20026
20027
20027
Z6028
10029
10030
20031
20032
20033
20035
20036
20037
200 38
26039
20341
20045
20053
20065
20077
20081
20085
20087
20091
20093
20116
20117
20119
20123
20124
20131
20139
20144
20183
20186
20189
ROCKBRIDGE CNTY SCHL 2740 8211
DRAGON CHEMICAL CO. 2720 2879
HENKEL-HARRIS CO.INC 1220 2511
FRAZIER QUARRYtINC. 2760 1422
ELKTON LIMESTONE INC 2760 1422
VA ASPHALT PAVING CO 7777 2951
LONE JACK LIMESTONE 7777 2951
CUPP BLACK TOPi INC. 7777 2951
ADAMS CONSTRUCTION 7777 2951
HERDON PAVING 7777 2951
FARRIER PAVING CO. 0260 2951
VALLEY PAVING CO 7777 2951
MOORE BROS. CO. 7777 2951
MOORE BROS. CO. 7777 2951
STEWART M.PERRYtINC. 1220 1422
JOHN A. HALL & CO. 7777 2951
SAWYER THOMAS CO. 7777 2951
VA. ASPHALT PAVING 7777 2951
ADAMS CONSTRUCTION 7777 2951
ADAMS CONSTRUCTION 7777 2951
S.R. DRAPER 7777 2951
ADAMS CONSTRUCTION 7777 2951
ADAMS CONSTRUCTION 7777 2951
LAYMAN AND SONS 7777 2951
BLAKEMORE CONSTR COR 7777 2951
ADAMS CONSTRUCTION 7777 2951
NATIONAL FRUIT PROD. 1220 2033
BUCKLEY-LAGES INC 7777 2951
HOLLY FARMS F'LTRY 2880 2015
UMC INDUSTRIES! INC. 2740 2641
VIRGINIA FOUNDRY CO 2720 3321
ELK TON PAVING*INC. 2760 2951
ROCCOiINC. 2760 2042
GROENDYK MFC CORP 0460 3069
AILEENi INC. 2880 2339
CHARLES W. BARGER 2740 1422
MADISON UNIVERSITY 2760 8221
COVINGTONi CITY OF 7777 2951
MOHAWK RUBBER CO 2720 3011
VA. POLYTECH. INST. 2020 8221
ROANOKE ELEC STEEL 2720 3313
JEFFERSON MILLS DIV. 25«0 2282
TRIANGLE E BYPRODUCT 2760 2042
RUBBERMAID COM. PROD 3380 3079
ROCKINGHAM POULTRY 2320 0250
AMERICAN SAFETY RAZ9 0260 3421
ELEMENTARY AND SECONDARY SCHOO
AGRICULTURAL CHEMICALSi NEC
MOOD HOUSEHOLD FURNITURE
CRUSHED AND BROKEN LIMESTONE
CRUSHED AND BROKEN LIMESTONE
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
CRUSHED AND BROKEN LIMESTONE
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
CANNED FRUITS AND VEGETABLES
PAVING MIXTURES AND BLOCKS
2015
PAPER COATING AND GLAZING
GRAY IRON FOUNDRIES
PAVING MIXTURES AND BLOCKS
GRAIN MILL PRODUCTS
FABRICATED RUBBER PRODUCTS NEC
WOMEN'S & MISSES OUTERWEAR NEC
CRUSHED AND BROKEN LIMESTONE
COLLEGES AND UNIVERSITIES* NEC
PAVING MIXTURES AND BLOCKS
TIRES AND INNER TUBES
COLLEGES AND UNIVERSITIES* NEC
ELECTROMETALLURG1CAL PRODUCTS
THROWING AND WINDING MILLS
GRAIN MILL PRODUCTS
MISCELLANEOUS PLASTICS PRODUCT
0250
CUTLERY
A-3
-------
QUICK LOOK REPORT
85/20/81
COMPLIANCE DATA SYSTEM
SPECIAL VIRGINIA RtGlON REPORT
STATE REG. NO.
SOURCE NAME
CN1Y SIC SIC CODE DESCRIPTION
20203
Z0208
20212
20214
20215
20225
20231
20232
20232
20237
20241
20244
20252
2026*3
20269
20271
20300
20302
20304
20320
20321
20322
20325
20326
20328
203Z9
20333
20334
20335
20337
20340
20341
20342
20381
20383
20391
20397
20405
20411
20412
20413
20417
20422
20429
20430
20430
BOND LUMBR & M1LMRK
C.S.MUNDYt QUARRIES
SINGER
KINGS DAUGHTER HOSP
CONCRETE READY MIXED
NATIONAL GYPSUM CO
LONE STAR INDUSTRIES
LONE STAR CEMENT
LONE STAR CEMENT COR
CROWN CORK 6 SEAL
JAMISON BLACK MARBLE
JW KALBACK & SONS
CHEMSTONE CORP
P.M.PLUMLY LUMBER CO
BURLINGTON IND
BURLINGTON IND INC
COLEMAN FURNITURE CO
OLD VIRGINIA BRICK
CELANESE FIBERS CO
JAMES R1V LIMESTONE
HOOVER COLOR CORP.
HERCULES » INC.
STUART M. F'ERRYi INC
STUART M PERRY* INC
WESTVACO CORP PULP
UESTVACO CHEM DIV
0' SULLIVAN CORP.
WALKER MACHN & FOUND
VA OAK TANNERY
WAYN-TEX
WEBL1TE CORP
VIRGINIA LIME CO
GEORGIA BONDLD FIBER
LYNCHBURG FOUNDRY
BUENA VISTA RDY MIX
PANTASOTE
SHELL OIL COMPANY
ZUCHERMAN CO. INC.
WAYNE MFC. CO.
WESTERN STATE HOSP
CROtlPTON-SHENLNUOAH
DAVIS PAVING CO
TAMCO MOTORS
VA LIMESTONE CORP
ABEX CORPORATION
ABEX CORPORATION
2760
2760
2720
0260
2720
1300
2720
0460
0460
1220
2760
1220
2880
1220
2740
2580
2580
2720
1300
0460
2580
2580
1220
1220
0100
0100
1220
2720
2320
0260
0460
1300
2740
2020
2740
0100
2720
1220
0260
0260
0260
7777
2320
1300
1220
1220
2512
1420
2511
8062
3273
3274
3241
3241
3241
3411
1429
2421
3274
2421
2271
2262
2511
3251
2823
3274
2816
2816
1422
1422
2621
2819
3079
3321
3111
2824
3295
3274
2200
3321
3273
3069
5171
3441
3442
8061
2299
2951
3621
1422
3292
3292
UPHOLSTERED HOUSEHOLD FURNITUR
CRUSHED AND BROKEN STONE
WOOD HOUSEHOLD FURNITURE
GENERAL MEDICAL t SURGICAL HOS
HEADY-MIXED CONCRETE
LIME
CEMENT i HYDRAULIC
CEMENT . HYDRAULIC
CEMENT. HYDRAULIC
METAL CANS
CRUSHED AND BROKEN STONE NEC
SAWMILLS fc PLANING MILLS GEN
LIME
SAWMILLS 6 PLANING MILLS GEN
WOVEN CARPETS AND RUGS
FINISHING PLANTSi SYNTHETICS
WOOD HOUSEHOLD FURNITURE
BRIC AND STRUCTURAL CLAY TILE
CELLULOSIC MAN-MADE FIBERS
LIME
INORGANIC PIGMENTS
INORGANIC PIGMENTS
CRUSHED AND BROKEN LIMESTONE
CRUSHED AND BROKEN LIMESTONE
PAPER MILLS EXC BUILDING PAPER
INDUSTRIAL INORGANIC CHEMICALS
MISCELLANEOUS PLASTICS PRODUCT
GRAY IRON FOUNDRIES
LEATHER TANNING AND FINISHING
ORGANIC FIBERS. NONCELLULOSIC
MINERALSt GROUND OR TREATED
LIME
2200
GRAY IRON FOUNDRIES
READY-MIXED CONCRETE
FABRICATED RUBBER PRODUCTS NEC
PETROLEUM BULK STATIONS fc TERM
FABRICATED STRUCTURAL METAL
METAL DOORS i SASHt AND TRIM
HOSPITALS
TEXTILE GOODS. NEC
PAVING MIXTURES AND BLOCKS
MOTORS AND GENERATORS
CRUSHED AND BROKEN LIMESTONE
ASBESTOS PRODUCTS
ASBESTOS PRODUCTS
A-4
-------
QUICK LOOK REPORT
05/20/61
COMPLIANCE DATA SYSTEM
SPECIAL VIRGINIA REGION REPORT
STATE REG. NO.
SOURCE NAME
CNTY SIC SIC CODE DESCRIPTION
20431
20432
20433
20434
20435
20437
20438
20439
20444
20447
20446
20450
20451
20452
20453
20454
20455
20456
20457
20458
10460
20461
20462
20468
20469
20470
20471
20475
20476
20477
2*1460
10461
20482
10484
20504
20510
20513
20515
20516
Z0517
20518
205? 1
20523
10523
20524
20524
RADFORD LIMESTONE t
RADFORD LIMESTONE 2
RADFORD LIMESTONE
RADFORD LIMESTONE 3
RADFORD LIMESTONE 4
HARDWOOD LUMBER CORP
TAYLOR RAMSEY
VULCAN MATERIALS
FLOW RESEARCH ANIMAL
WEBSTER BRICK
SOUTHERN STATES COOP
BLUE RIDGE STONE
HARRIS HARDWOOD CO.
M J GROVE LIME CO
M.J. GROVE LIME CO.
ALLIED CHEMICAL CORP
ALLIED CHEM CORP
ROCK YD ALE QUARRIES
ROCKYDALE QUARRIES
JAMES RIV LIMESTONE
APP POWER-GLEN LYN
STATE STONE CORP
STATE STONE CORP
NORFOLK & WESTERN
RELIANCE UNIV.
PULASKI FURNITURE
LONE JACK LIMESTONE
AVTEX
BR1DGEWATER COLLEGE
VETERANS ADMIN. HOS.
STANLEY FURNITURE
STANLEY FURNITURE
ACCO STONE
ADAMS CONST. CO
W.S. FPEY CO.i INC.
HERCULES
ROCK1NGHAM MILLING
REYNOLDS METAL CO
REEVES BROS VULCAN
E.I DUPONT
VA. METALCRAFTERS
POTOMAC ED-RIVER TON
WELLS FURNITURE CO
WELLS FURN.
MERCKfcCO.INC.CHEM DV
MERCKfcCO.lNCfCHEM DV
2580
2580
2020
2020
2020
1540
2740
0260
2580
0460
2720
0460
2720
1220
1220
3260
2580
2720
2720
0460
1300
2720
1300
2720
2720
2580
2740
3260
2760
2720
0260
0260
7777
7777
1220
0100
2760
0260
2740
0260
0260
3260
2720
2720
2760
2760
1422
1422
1446
1422
1422
2421
2421
3295
8999
3251
2042
1422
2426
1422
3295
2819
2819
1422
3274
3274
4911
1422
1422
3743
2851
2511
1422
2823
8221
8062
25] 1
2421
1422
1422
1422
2821
2042
2821
3069
2824
3446
4911
2500
2511
2834
2834
CRUSHED AND BROKEN LIMESTONE
CRUSHED AND BROKEN LIMESTONE
INDUSTRIAL SAND
CRUSHED AND BROKEN LIMESTONE
CRUSHED AND BROKEN LIMESTONE
SAWMILLS & PLANING MILLS GEN
SAWMILLS t PLANING MILLS GEN
MINERALS. GROUND OR TREATED
SERVICES! NEC
BR1C AND STRUCTURAL CLAY TILE
GRAIN MILL PRODUCTS
CRUSHED AND BROKEN LIMESTONE
HARDWOOD DIMENSION & FLOORING
CRUSHED AND BROKEN LIMESTONE
MINERALSi GROUND OR TREATED
INDUSTRIAL INORGANIC CHEMICALS
INDUSTRIAL INORGANIC CHEMICALS
CRUSHED AND BROKEN LIMESTONE
LIME
LIME
ELECTRICAL SERVICES
CRUSHED AND BROKEN LIMESTONE
CRUSHED AND BROKEN LIMESTONE
RAILROAD EQUIPMENT
PAINTS AND ALLIED PRODUCTS
WOOD HOUSEHOLD FURNITURE
CRUSHED AND BROKEN LIMESTONE
CELLULOSIC MAN-MADE FIBERS
COLLEGES AND UNIVERSITIES* NEC
GENERAL MEDICAL & SURGICAL HOS
WOOD HOUSEHOLD FURNITURE
SAWMILLS & PLANING MILLS GEN
CRUSHED AND BROKEN LIMESTONE
CRUSHED AND BROKEN LIMESTONE
CRUSHED AND BROKEN LIMESTONE
PLASTICS MATERIALS AND RESINS
GRAIN MILL PRODUCTS
PLASTICS MATERIALS AND RESINS
FABRICATED RUBBER PRODUCTS NEC
ORGANIC FIBERS. NONCELLULOSIC
ARCHITECTURAL METAL WORK
ELECTRICAL SERVICES
2500
WOOD HOUSEHOLD FURNITURE
PHARMACEUTICAL PREPARATIONS
PHARMACEUTICAL PREPARATIONS
A-5
-------
QUICK LOOK REPORT
05/20/81
COMPLIANCE DATA SYSTEM
SPECIAL VIRGINIA RtGION REPOR1
STATE REG. NO.
SOURCE NAME
CNTY SIC SIC CODE DESCRIPTION
20526
20529
20542
20544
20548
20549
20552
20553
20560
20565
20569
20570
20572
20576
20581
20590
20592
20596
20600
20609
20655
20656
20668
20675
20676
20677
20679
20680
20681
20683
20684
20688
20697
20698
20709
20711
20717
20723
20733
20735
20742
20763
20764
£0765
20771
20786
BLPtlNC.
GENERAL SHALE PROD.
GENERAL ELECTRIC
KOPPERS CO.
ETHAN ALLEN INC
ROANOKE READY-MIX
ROANOKE READY-MIX
MAMPLER FOODSiINC.
WHITE FOUNDRY CO.INC
LUCK QUARRY
JAMES RIV LIMESTONE
RIVERTON CORP
GENERAL ELECTRIC
C «. 0 RAILWAY CO.
POFF CONSTRUCTION
CATAWBA HOSPITAL
GENERAL ELECTRIC CO.
LEAS & MCVITTEY INC
ROCK1NCHAM MEM.HGSP
DOMINION SILOt INC.
RE A MAG. MIRE
RADFORD ARMY AMMO PT
RIVERTON CORP.
VEPCO
C S MUNDY QUARRY
C S MUNDY QUARRIES
JOHN HANDLEY UGH SCH
WINCHESTER INTER SCH
QUARLES ELEM SCHOOL
JOHN KERR MIDDLE SCH
ATLANTIC LUMBER
FORECAST FURNITURE
UNIMIN CORP.
STAR FOUNDRY PRODUCT
BURKE-PARSONS-BOWLBY
MENNEL MILLING CO.
DUNCAN BROS TIRt CO.
SHENANDOAH BRICK
HARDEE'S
GALL IMORE PAVING CO
GRAHAM-WHITE MFC CO.
WOLVERINE
JOHNS-MANVILLE
WHITE MOTOR
QUALITY FEEDS. INC.
ROCKINCHAM POULTRY
2580 2295 COATED FABRICS. NOT RUBBERIZED
2740 3251 BRIC AND STRUCTURAL CLAY TILE
2720 3622 INDUSTRIAL CONTROLS
2720 2491 WOOD PRESERVING
2760 2511 WOOD HOUSEHOLD FURNITURE
2720 3273 READY-MIXED CONCRETE
2720 3273 READY-MIXED CONCRETE
2760 2042 GRAIN MILL PRODUCTS
2720 3321 GRAY IRON FOUNDRIES
0260 1422 CRUSHED AND BROKEN LIMESTONE
0460 3274 LIME
3260 3295 MINERALS. GROUND OR TREATED
3320 3479 METAL COATING AND ALLIED SERVI
0100 4000 4000
2020 1500 1500
2720 8062 GENERAL MEDICAL fc SURGICAL HOS
2800 3622 INDUSTRIAL CONTROLS
2720 3111 LEATHER TANNING AND FINISHING
2760 8062 GENERAL MEDICAL S, SURGICAL HOS
2760 3272 CONCRETE PRODUCTSi NEC
2740 3357 NONFERROUS WIRE DRAWING/INSULA
2020 9711 NATIONAL SECURITY
3260 1422 CRUSHED AND BROKEN LIMESTONE
0100 4911 ELECTRICAL SERVICES
2880 1420 CRUSHED AND BROKEN STONE
7777 2951 PAVING MIXTURES AND BLOCKS
1220 6211 ELEMENTARY AND SECONDARY SCHOO
1220 8211 ELEMENTARY AND SECONDARY SCHOO
1220 8211 ELEMENTARY AND SECONDARY SCHOO
1220 8211 ELEMENTARY AND SECONDARY SCHOO
2740 2421 SAWMILLS 8. PLANING MILLS GEN
1220 2512 UPHOLSTERED HOUSEHOLD FURNITUR
1220 3295 MINERALS? GROUND OR TREATED
2720 3321 GRAY IRON FOUNDRIES
2740 2491 WOOD PRESERVING
2720 2041 FLOUR & OTHER GRAIN MILL PROD
1220 3011 TIRES AND INNER TUBES
1220 1459 CLAY AND RELATED MINERALS NEC
2020 5812 EATING PLACES
2580 2951 PAVING MIXTURES AND BLOCKS
2720 3741 3741
2020 3293 GASKETS/PACKING/SEALING DEVICE
2880 2661 BUILDING PAPER AND BOARD MILLS
2580 3713 TRUCK AND BUS BODIES
2760 2042 GRAIN MILL PRODUCTS
2760 2042 GRAIN MILL PRODUCTS
A-6
-------
QUICK LOOK REPORT
05/20/81
COMPLIANCE DATA SYSTEM
SPECIAL VIRGINIA REGION REPORT
STATE REG. NO.
SOURCE NAME
CNTY SIC SIC CODE DESCRIPTION
20789
20794
20794
20796
20797
20826
20826
20830
20632
20834
20635
20872
20878
20878
20680
20883
20688
20904
20911
20914
20921
20937
20957
20971
20972
20972
20960
20982
20991
20995
30WT
30010
30020
300Z1
30022
30024
30026
30028
30029
30030
30031
30041
30042
30043
30053
30064
PULASKI FURNTRE CORP 2580 2511
STAUNTON LIME CO. 0160 2812
STAUNTON LIMESTONE 0260 1422
SISSON (, RYAN 2020 2351
SISSON & RYAN 2020 1422
D.C. HEATMOLE CO. 2760 7534
VA. HOT SfRINGS 0300 7011
CAMELOT HALL NURSING 2720 8050
HERSHEY TIRE COMPANY 0260 7534
VEPCO 0300 4910
BOISE CASCADE 0760 2434
CHEMSTONE CORP. FEV 2860 3399
VA LIME CO-FOOTE M1N 1300 3274
VIRGINIA LIME 1300 3295
CARR'S TIRE DIST.INC 2760 5014
L.H.SAWYER PAVING CO 77/7 2951
CYCLE SYSTEMS INC 2720 3341
MCVITTY HOUSE 2720 8361
BLACKSBURG SANI AUTH 2020 4952
ADAMS CONSTRUCTION 2020 2951
U.S. POSTAL SERVICE 1220
FIRST NAT'L EXC BANK 2720 6025
SALEM, CITY 2720 4953
ADAMS CONSTRUCTION 2740 2951
A.N. JOHNSTON 2760 2951
A.N. JOHNSTON 7777 2951
LEE HY PAVING 1220 2951
WEST SAND & GRAVEL 2760 1422
EXXON 2720 5171
MARATHON OIL 2720 5171
AMELIA LUMBER CORP. 0140 2421
W.C.MORGAN LUMBER CO 1980 2420
SHORT PAVING CO..INC 7777 2951
LAWHORNE BROS. 7777 2951
M.V.TEMPLETON.INC. 7777 2951
ADAMS CONSTRUCTION 7777 2951
M.V.TEMPLETON INC 7777 2951
DAYSTROM FURN CO. 1420 2512
THOMPSON ART PAVING 7777 2951
THOMPSON ARTH PAVING 7777 2951
THOMPSON ANT PAVING 7777 2951
JP STEVENS & CO INC 1200 2221
V.M.DRAPER MFG. 1520 2426
ANDERSON LUMBER CO 0140 2421
BARNES LUMBER CORP. 0540 2426
JP STEVENS & CO 1200 2511
WOOD HOUSEHOLD FURNITURE
ALKALIES AND CHLORINE
CRUSHED AND BROKEN LIMESTONE
MILLINERY
CRUSHED AND BROKEN LIMESTONE
TIRE RETREADING AND REPAIR SHO
HOTELSr MOTELSf AND TOURIST CO
6050
TIRE RETREADING AND REPAIR SHO
4910
WOOD KITCHEN CABINETS
PRIMARY METAL PRODUCTS, NEC
LIME
MINERALS, GROUND OR TREATED
TIRES AND TUBES
PAVING MIXTURES AND BLOCKS
SECONDARY NONFERKOUS METALS
RESIDENTIAL CARE
SEWERAGE SYSTEMS
PAVING MIXTURES AND BLOCKS
NATIONAL BANKS, FEDERAL RESERV
REFUSE SYSTEMS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
CRUSHED AND BROKEN LIMESTONE
PETROLEUM BULK STATIONS fc TERM
PETROLEUM BULK STATIONS & TERM
SAWMILLS ft PLANING MILLS GEN
2420
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
UPHOLSTERED HOUSEHOLD FURNITUR
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
WEAVING MILLS, SYNTHETICS
HARDWOOD DIMLNSION 8, FLOORING
SAWMILLS t PLANING MILLS GEN
HARDWOOD DIMENSION & FLOORING
WOOD HOUSEHOLD FURNITURE
A-7
-------
QUICK LOOK REPORT
05/20/61
COMPLIANCE DATA SYSTEM
SPECIAL VIRGINIA REGION REPORT
STATE REG. NO.
SOURCE NAME
CNTY SIC SIC CODE DESCRIPTION
30068
30069
30076
30061
30093
30097
30103
30106
30118
30 120
30121
30 122
30123
30124
30126
30130
30133
30151
30155
30171
30173
30175
30161
30163
30164
30165
30166
30168
30193
30200
30211
30215
30218
30219
30228
30229
30230
30231
30232
30233
30240
30241
30243
30246
30249
30253
J.P.STEVENS & CO INC 1420 2221 WEAVING MILLSt SYNTHETICS
DANVILLE POWER PLANT 2380 4910 4910 .
CONTINENTAL CAN CO. 1520 2653 CORRUGATED AND SOLID FIBER BOX
COMMODORE CORP. 2380 3791 3791
VIRGINIA CRAFTS. INC. 0660 2272 TUFTED CARPETS AND RUGS
AMERICAN FURNITURE 1520 2512 UPHOLSTERED HOUSEHOLD FURNITUR
SOUTHERN FACILITIES 0340 5171 PETROLEUM BULK STATIONS t TERM
GOODYEAR TIRE&RUBBER 2380 2822 SYNTHETIC RUBBER
STAR PAPER TUBE INC 2380 2655 FIBER CANS DRUMS LIKE PRODUCTS
WHITTLE PLYWOOD CORP 2380 2430 2430
LYNCHBURG FOUNDRY 0580 3321 GRAY IRON FOUNDRIES
BUFFALO SHOOK 2480 2449 WOOD CONTAINERS* NEC
PIEDMONT MILLS. INC. 0560 2041 FLOUR & OTHER GRAIN MILL PROD
MEREDITH/BURDA 0580 2751 COMMERCIAL PRINTING LETTERPRES
ROSS LABORATORIES 0560 2833 MEDICINALS AND BOTANICALS
CHAMPION BUILD. PROD 1420 2436 SOFTWOOD VENEER AND PLYWOOD
PHILLIPS PETROLEUM 0340 5171 PETROLEUM BULK STATIONS t TERM
HANSON PORCELAIN CO. 0580 3461 3461
SOUTHS IDE MFG. CO. 2360 2531 PUBLIC BUILDING t RELATED FURN
GRAVELY FURNITURE 1520 2511 WOOD HOUSEHOLD FURNITURE
HOMECRAFT CORP 1980 3791 3791
DOYLE READY-MIX CONC 1520 3273 READY-MIXED CONCRETE
FIELDCREST MILLS 1520 2211 WEAVING MILLSt COTTON
MARTINSVILLE NOVELTY 1520 2511 WOOD HOUSEHOLD FURNITURE
BARNES MFG. CO. 1600 2421 SAWMILLS t PLANING MILLS GEN
IMPERIAL BRIQUET COR 1600 2861 GUM AND WOOD CHEMICALS
SMITH- DOUGLASS 2360 2871 2871
MEAD CP (LNCHBG BRD) 0560 2631 PAPERBOARD MILLS
ROCKYDALE QUARRIES 0580 3295 MINERALS. GROUND OR TREATED
SOLITE CORPORATION 0540 1429 CRUSHED AND BROKEN STONE NEC
HALIFAX COTTON MILLS 1420 2211 WEAVING MILLS. COTTON
ALLEN MORRISON 0580 3993 SIGNS AND ADVERTISING DISPLAYS
BURRUSS LAND ft LUMBR 0580 2426 HARDWOOD DIMENSION & FLOORING
BURRUSS LAND 6 LUMBR 0580 2426 HARDWOOD DIMENSION 8, FLOORING
TEXACO. INC. 0340 5171 PETROLEUM BULK STATIONS 6 TERM
BLUE RIDGE TALC CO 1520 2851 PAINTS AND ALLIED PRODUCTS
HOLLY FARMS POULTRY 2260 0259 POULTRY AND EGGS NEC
LYNCHBURG FOUNDRY CO 0580 3321 GRAY IRON FOUNDRIES
AMOCOtlNC. 0340 5171 PETROLEUM BULK STATIONS t TERM
LESTER LUMBER CO INC 1520 2426 HARDWOOD DIMENSION fc FLOORING
DAN RIVER. INC. 2360 2211 WEAVING MILLS. COTTON
DAN RIVER MILLS 2360 2211 WEAVING MILLSi COTTON
TULLY CORPORATION 1420 2800 CHEMICALS AND ALLIED PRODUCTS
LANE CO.. INC. 0560 2511 WOOD HOUSEHOLD FURNITURE
FELTON BROS TRAN MIX 1420 3271 CONCRETE BLOCK AND BRICK
DOYLE LUMBER. INC 1520 2421 SAWMILLS fc PLANING MILLS GEN
A-8
-------
QUICK LOOK REPORT
09/20/81
COMPLIANCE DATA SYSTEM
SPECIAL VIRGINIA REGION REPORT
STATE REG. NO.
SOURCE NAME
CNTY SIC SIC CODE DESCRIPTION
-30260
30261
30264
30266
30279
30280
30283
30284
30285
30286
30287
30288
30289
30291
30296
30297
30318
30319
30520
30321
30327
30328
30330
30349
30356
30358
30359
30360
30361
30362
30364
30365
30366
30378
30379
30381
30386
30387
30388
30389
30392
30394
30395
30396
30397
36401
BABCOCK t WILCOX
HOOKER FURNITURE
C1TGO.INC
BURLINGTON INDUSTRIE
LANE COMPANY
LANE CO. i INC.
DAN RIVER F INC.
BttSSETT TABLE CO
BASSETT SUPERIOR
BASSETT FURNITURE
BASSETT FURNIUR IND
BASSETT FURNITURE
BASSETT FURNITUR PLT
APPOMATTOX LIME CO
RUBATEX CORP
SOLITE CORP
WEST SAND&GRAVEL CO.
STANLEY FURNITURE CO
STANLEY FURNITURE CO
E.I.DUPONT
J.P. STEVENS & CO.
J.P.STEVENS & CO INC
U.S. GYPSUM CO.
RAILWAY HANDLE CORP.
MARTINSVILLE STONE
BLUE RIDGE STONE
BUTLER LUMBER CO
LONGWOOD COLLEGE
KYANITE MINING CORP
KYANITE MINING CORP.
KYANITE MINING COR»'
KYANITE MINING CORP.
APPOMATTOX LIME CO.
BURLINGTON IND.
BURLINGTON INDUST
NATIONAL HOME MANU
MM MANUFACTURERS
FRANKLIN VENEER CO
GUYER-ROBERTS MANUF
OWENS ILLINOIS
ERATH VENEER CORP.
VULCAN MATERIALS
VULCAN MATERIALS
VULCAN MATERIALS CO.
GRIFFIN PIPE PRTS CO
BURLINGTON INDUST
0580
1520
0340
1420
1200
1200
2380
1520
1520
1520
1520
1520
1520
0180
0340
2330
0500
1200
1520
1520
2340
2340
2380
1800
1520
0580
19E:0
24:30
2480
0540
0540
2480
0180
0560
2380
1520
1200
1200
1200
0340
1200
1420
0500
2380
0560
1960
2819
2511
5171
2221
2511
2511
2211
2511
2511
3700
2511
2511
3027
2621
3069
3251
1429
2511
2541
2824
2241
2241
3275
2491
3295
1422
2420
8221
1459
1459
1459
1459
6211
2231
2262
2433
2431
2436
2499
2631
2436
1423
1423
1423
3321
2299
INDUSTRIAL INORGANIC CHEMICALS
WOOD HOUSEHOLD FURNITURE
PETROLEUM BULK STATIONS t TERM
WEAVING MILLSi SYNTHETICS
WOOD HOUSEHOLD FURNITURE
WOOD HOUSEHOLD FURNITURE
WEAVING MILLSi COTTON
WOOD HOUSEHOLD FURNITURE
WOOD HOUSEHOLD FURNITURE
3700
WOOD HOUSEHOLD FURNITURE
WOOD HOUSEHOLD FURNITURE
3027
PAPER MILLS EXC BUILDING PAPER
FABRICATED RUBBER PRODUCTS NEC
BRIC AND STRUCTURAL CLAY TILE
CRUSHED AND BROKEN STONE NEC
WOOD HOUSEHOLD FURNITURE
WOOD PARTITIONS AND FIXTURES
ORGANIC FIBERSi NONCELLULOSIC
NARROW FABRIC MILLS
NARROW FABRIC MILLS
GYPSUM PRODUCTS
WOOD PRESERVING
MINERALSi GROUND OR TREATED
CRUSHED AND BROKEN LIMESTONE
2420
COLLEGES AND UNIVERSITIES? NEC
CLAY AND RELATED MINERALS NEC
CLAY AND RELATED MINERALS NEC
CLAY AND RELATED MINERALS NEC
CLAY AND RELATED MINERALS NEC
ELEMENTARY AND SECONDARY SCHOO
WEAVING fc FINISHING MILLS WOOL
FINISHING PLANTS) SYNTHETICS
2433
MILLWORK
SOFTWOOD VENEER AND PLYWOOD
WOOD PRODUCTS) NEC
PAPERBOARD MILLS
SOFTWOOD VENEER AND PLYWOOD
CRUSHED AND BROKEN GRANITE
CRUSHED AND BROKEN GRANITE
CRUSHED AND BROKEN GRANITE
GRAY IRON FOUNDRIES
TEXTILE GOODS) NEC
A-9
-------
QUICK LOOK REPORT
05/20/61
COMPLIANCE DATA SYSTEM
SPECIAL VIRGINIA REGION REPORT
STATE REG. NO.
SOURCE NAME
CNTY SIC SIC CODE DESCRIPTION
30402
30409
30413
30415
30418
30419
30444
30447
30451
30452
30457
30458
30459
30462
30463
30476
30480
30510
30514
30515
30517
30538
30540
30541
30542
30544
30545
30549
30579
30585
30591
30592
30594
30616
30676
30679
30691
30692
HENRY CO PLYWOOD 1520 2499
BASSETT-WALKER KNTNG 1520 2253
LUCK QUARRIES 2260 1423
COLONIAL PIPELINE CO 0900 4600
BASSETT-WALKER KNTTG 1520 1900
GENERAL ELECTRIC CO. 0560 366Z
BOISE CASCADE CORP 2380 2432
H.S.NASH LUMBER CORP 0580 2426
PIEDMONT STATE HOSP 2260 6061
LYNCHBURG TRAIN SCHL 0160 8200
BASSETT VENEER CORP 0160 2436
BASSETT VENEER CORP 2260 2435
BRUNSWICK BOX CO. 0500 2499
MQSELEYS.NASH ENTER. 0500 2221
LONE STAR IND. 0500 3273
STUART LUMBER CORP 2340 2421
DOLLY MADISON INC 2260 2512
WILSON QUARRIES 1520 3251
DISSTON.INC 2360 3425
PULASKI FURNITURE 1520 2511
DUNNINGTON-BEACM TOB 2480 3523
ARVONIA BUCKHM.SLATE 0540 1429
FELTON BROS TRAN MIX 7777 2951
FELTON BROS TRAN MIX 1980 3273
FELTON BROS TRAN MIX 1980 3273
FELTON BROS TRAN MIX 1980 3273
FELTON BROS TRAN MIX 7777 2951
VA. FIBRE CORP. 0160 2621
BUTLER LUMbER CO. 0500 2441
FREEMAN CHEM. CORP. Z380 2821
ROY N. FOKDiINC 7777 2951
FALWELL ASP8EXCAV.CO 7777 2951
DEESLEE PAVING CO. 0660 1610
TRANSMARK OPERATIONS 0180 2511
MOSELEY & NASH ENTPS 0500 2221
HENRY CO PUBLIC SCHL 1520 8211
AMER.FURNITURE PLT10 1520 2M1
AM. FURN. PLANT6i7>8 1520 2511
MOOD PRODUCTS* NEC
KNIT OUTERWEAR MILLS
CRUSHED AND BROKEN GRANITE
4600
1900
RADIO/TV COMMUNICATION EQUIPMN
2432
£420
HOSPITALS
8200
SOFTWOOD VENEER .AND PLYWOOD
HARDWOOD VENEER AND PLYWOOD
WOOD PRODUCTSi NEC
WEAVING MILLS, SYNTHETICS
READY-MIXED CONCRETE
SAWMILLS & PLANING MILLS GEN
UPHOLSTERED HOUSEHOLD FURNITUR
BRIC AND STRUCTURAL CLAY TILE
HAND SAWS AND SAW BLADES
WOOD HOUSEHOLD FURNITURE
FARM MACHINERY AND EQUIPMENT
CRUSHED AND BROKEN STONE NEC
PAVING MIXTURES AND BLOCKS
READY-MIXED CONCRETE
READY-MIXED CONCRETE
READY-MIXED CONCRETE
PAVING MIXTURES AND BLOCKS
PAPER MILLS EXC BUILDING PAPER
NAILED WOOD BOXES AND SHOOK
PLASTICS MATERIALS AND RESINS
PAVING MIXTURES AND BLOCKS
PAVING MIXTURES AND BLOCKS
1610
WOOD HOUSEHOLD FURNITURE
WEAVING MILLSi SYNTHETICS
ELEMENTARY AND SECONDARY SCHOO
WOOD HOUSEHOLD FURNITURE
WOOD HOUSEHOLD FURNITURE
TOTAL NUMBER QUICK LOOK REPORT LINES
• 360
A-10
-------
APPENDIX B
SUMMARY OF COMPLIANCE STATUS
FOR SOURCES IN REGION II
B-l
-------
QUICK LOOK REPORT
11/04/81 COMPLIANCE DftTA SYSTEM1 F^CE 1
QUICK LOOK SUMMARY REGION II
TuTE r.EO. .«. SOURCE NfiilL SIC CMST ECAT AT PE DATt SCH ACTION DESCKIP STfiT DATE ACH RESULTS DtSCRIP PURS
03
oo
-------
20001
DRAGON CHEMICAL CO. 2879 3
CO
20021
20021
20023
20024
FRAZIER QUARRYiINC. 1422 4
ELKTON LIrtESTONE INC 1422 3
LONE JACK LIMESTONE 2951 4
CUPP BLACK TOPi INC. 1951 3
ADAMi CONSTRUCTION 2951 3
WELLS CONSTRUCTION 2951 4
08 10/31/81
08 09/30/80
08 09/S0/81
08 09/30/82
08 09/30/60
08 09/30/81
08 09/30/82
08 09/30/80
1™ 09/30/61
08 09/30/81
08 . 09/30/62
08 09/30/80
08 09/30/81
08 09/30/82
08 09/30/80
08 09/30/81
08 09/30/82
06 09/30/80
08 09/30/81
08 09/30/82
08 09/30/80
49 09/30/81
08 09/30/81
STATE IKSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
EPA OVR INSPECT
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N
STATE INSCECT'N
STATE INSPECT'N
STATE INSPECT'N 3*
STATE INCPECT'N
STATE'INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 41
EPA OVR INSPECT 30
STATE INSPECT'N
03/12/80 IN COMPLIANCE
10/09/81 IN COMPLIANCE
09/12/80 IN COMPLIANCE
05/19/80 IN COMPLIANCt
10/03/79
04/10/80 IN COMPLIANCE
11/14/79 IN COMPLIANCE
09/30/80 NOT IN OPEKAT10
09/10/81 IN COMPLIANCE
-------
20025
FARRIER PAVING CO. 2951 3 2
co
i
en
20029
20030
28631
20032
VALLEY PAVING CO 2951 A 3
MOOKE BROS. CO. 2951 3 2
JOHN A. HALL & CO. 2951 3
SAWYtR THOMAS CO. 2951 9
Vft. ASPHALT PAVING 2951 3 3
ADAMS CONSTRUCTION 2951 4 2
08 09/30/82 STATE
08 05/31/82 STATE
08 09/30/80 STATE
08 09/30/81 STATE
08 09/30/82 STATE
08 ' 09/30/80 STATE
08 09/30/81 STATE
08 09/30/82 STATE
08 05/31/81 STATE
08 09/30/80 STATE
08 09/30/81 STATE
08 09/30/82 STATE
08 09/30/80 STATE
08 09/30/81 STATE
08 09/30/82 STATE
08 09/30/80 STATE
08 09/30/81 STATE
08 09/30/82 STATE
08 09/30/80 STATE
08 09/30/81 STATE
08 09/30/82 STATE
08 11/31/81 STATE
08 09/30/80 STATE
INSPECT'N
INSPECT'N
INSPECT'N 30
INSPECT'N 30
INSfECT'N
INSPECT'N 41
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N 30
INSPECT'N 30
INSfECT'N
INSPECT'N 30
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N 30
INSPECT'N
INSPCCT'N
INSPECT'N
INSPECT'N 30
09/12/80 IN COMPLIANCE
05/11/81 IN COMPLIANCE
09/03/80 NOT IN OPERATIC
09/10/80 IN COMPLIANCE
05/11/81 IN COMPLIANCE
06/13/80 IN COMPLIANCE
05/07/80 IN COMPLIANCE
11/05/80 IN COMPLIANCE
-------
ADAMS CONSTRUCTION 2951 4
20035
20636
S.R. DRAPER
2951 3
ADAMS CONSTRUCTION 2951 3
I
O-v
20037
20038
ADAMS CONSTRUCTION 2951 9
LAYMAN AND SONS 2951 4
08 09/30/81 STATE INSPECT'N
06 09/30/82 STATE INSPECT'N
08 10/31/81 STATE INSPECT'N 41
08 06/33/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N
49 09/30/81 EPA OVR INSPECT
08 09/30/61 STATE INSPECT'N 30
06 09/30/62 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N 30
08 09/30/81 STATE INSPECT'N
08 09/30/82 STATE INSPECT'N
08 04/15/81 STATE INSPECT'N 33
06 09/30/80 STATE INSPECT'N
08 09/30/81 STATE INSPECT'N 30
49 09/30/80 EPA OVR INSPECT 30
06 04/30/82 STATE INSPECT'N
08 09/30/82 STATE" INSPECT'N
08 09/30/60 STATE INSPECT'N
08 09/30/61 STATE INSPECT'N
08 09/30/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N
08 09/30/81 STATE INSPECT'N
06 09/30/82 STATE INSPECT'N
04/14/81 NOT IN OPERATIC
10/02/60 IN COMPLIANCE
08/08/80 IN COMPLIANCE
04/15/81 IN COMPLIANCE
00/00/00
10/16/80 IN COMPLIANCE
06/25/60 IN COMPLIANCE
-------
20038
20041
20077
co
£0085
20037
LAYMAN AND SONS 2951 2
BLAKEMORE CONSTR COR 2951 3
ADAMS CONSTRUCTION 2951 3
UMC INDUSTRIES. INC. 2641 4
VIRGINIA FOUNDRY CO 33,11 1
ELKTON PAVING,INC. 2951 3
ROCCOiINC. 2042 3
CHARLES W. BARGER 1422 4
08
08
08
08
06
49
08
08
08
08
08
06
09
Z2
08
08
08
08
08
03
08
08
08
09/30/81
09/30/82
09/30/80
09/30/81
09/30/80
09/30/80
09/30/81
09/30/82
01/31/82
09/30/80
09/30/81
09/30/82
08/31/81
08/31/81
09/30/81
09/30/82
09/30/80
09/30/81
09/30/80
09/30/81
09/30/82
09/30/60
09/30/81
STATE -INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPCCT'N 30
EPA OVR INSPECT
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSKECT'N
STATE VE TEST 10
NOTICE OF NON-C 11
STATE INSPECT'N
STATE INSPLCT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
E10
07/25/80 IN COMPLIANCE
06/17/60 IN COMPLIANCE
01/14/81 IN COMPLIANCE
/ /
08/31/31 OUT OF COilPLIAN
08/31/81 OC SCHED REQ
/ /
/ /
05/19/80 IN COMPLIANCE
/ /
08/07/80 IN COMPLIANCE
/ /
/ /
02/25/60 IN COMF'LIANCE
-------
20117
2011*
Z0123
DO
00
20123
20124
20131
MADISON UNIVERSITY 8221 4
COVINGTONr CITY 01 2951 4
MOHAWK RUBBER CO 3011 3
MOHAWK RUBBER CO 3011 5 2
VA. POLYTECH. INST. 8221 3 3
ROANOKE ELEC STEEL 3313 3
08 09/30/82
08 09/30/80
03 09/30/61
08 09/30/82
08 09/30/80
08 09/30/81
08 09/30/82
08 02/28/82
08 09/30/80
49 09/30/81
08 09/30/81
08 09/30/82
08 09/30/82
08 07/31/81
08 09/30/80
08 09/30/81
08 09/30/82
08 09/30/80
08 09/30/81
08 06/09/81
08 04/30/61
50 06/30/81
08 09/30/62
STATE'INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
EPA OVR INSPECT
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPtCT'N 39
t
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N 10
STATE INSPECT'N
EPA INSPECTION 10
STATE INSPECT'N
12/17/79 IN COMPLIANCE
03/15/80 IN COMPLIANCE
06/30/80 IN COMPLIANCE
02/05/81 IN COMPLIANCE
04/28/80 IN COMPLIANCE
05/26/81 IN COMPLIANCE
00/00/00
10/02/80 IN COMPLIANCE
06/09/81 OUT OF COMPLIAN
06/17/81 OUT OF COMPLIAN
-------
20183
RUBBERMAID COM. PROD 3079 3
AMERICAN SAFETY RAZ9 3421 3
C.S.MUNDYi QUARRIES 1420 3
U3
I
20212
SINGER
2511 4
20225
NATIONAL GYPSUM CO 3274 3
08
08
08
08
08
08
08
08
08
08
08
06
08
08
08
08
08
08
08
08
08
08
08
09/30/80
09/30/81
04/23/81.
10/31/81
09/30/82
' 09/30/80
09/30/81
05/31/82
09/30/82
09/30/80
09/30/81
09/30/82
11/31/81
09/30/80
09/30/81
09/30/82
02/05/81
02/28/82
04/14/81
04/30/82
05/13/81
05/31/82
01/05/81
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSP.ECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
30
30
30
30
30
30
30
30
30
30
00/00/00
01/29/81 IN COMPLIANCE
04/23/81 IN COMPLIANCE
09/23/80 IN COMPLIANCE
05/05/81 IN COMPLIANCE
06/12/60 Irf COMPLIANCE
11/06/80 IN COMPLIANCE
02/05/81 IN COMPLIANCE Eld
04/14/81 IN COMPLIANCE
05/13/81 IN COMPLIANCE
01/05/81 IN COMPLIANCE
-------
£0231
20231
LOME STAR INDUSTRIES 3241 4
LOME STAR CEMLNT 3241 3
DO
I
20241
20169
JAMISON BLACK MARELE 14^ 4
BURLINGTON IND
2271 4
20271
BURLINGTON IND INC 2262 3
1
3
1
3
•
2
08
06
08
06
50
50
tUft
Wo
08
08
08
03
08
50
90
06
08
08
08
08
08
08
08
08
01/31/62 STATE INSPECT»N / /
09/30/80 STATE INSPECT'N 00/00/00
09/30/81 STATE INSPECT'N 30 11/08/60
10/14/80 SOURC OP ST TES 30 10/14/80
11/06/60 EPA INSPECTION 30 11/06/80
09/30/80 EPA INSPECTION 30 10/14/80
09/30/82 STATE INSPECT'N / /
09/30/80 STATE INSPECT'N / /
02/12/81 STATE INSPECT'N 30 02/12/61
09/30/80 STATE INSPECT'N 30 05/20/80
03/31/82 STATE INSPECT'N / /
09/30/81 STATE INSPECT'N / /
05/01/91 EPA INSPECTION / /
00/00/99 EPA INSPECTION / /
09/30/82 STATE INSPECT'N / /
09/30/80 STATE INSPECT'N / /
09/30/81 STATE INSPECT'N / /
09/30/82 STATE INSFECT'N / /
09/30/80 STATE INSPECT'N / /
09/30/81 STATE INSPECT'N 30 02/05/81
02/28/62 STATE INSPECT'N / /
09/30/82 STATE INSPECT'N / /
i . m
07/03/61 STATE INSPECT'N / /
IN COMPLIANCE
IN COMPLIANCE
IN COMPLIANCE
IN COMPLIANCE
IN COMPLIANCE
IN COMPLIANCE
IN COMPLIANCE
-------
Z3300
£0302
20304
20320
20321
COLEMAN FURNITURE CO 2511 3
OLD VIRGINIA BRICK 3251 4
CELANESE FIBERS CO 2823 3
JAMES RIV LIMESTONE 3274 3
HOOVER COLOR CORP. 2816 3
08
08
08
08
08
08
08
08
08
08
08
08
08
08
08
08
08
08
08
06
08
08
08
09/30/80
09/30/81
09/30/82
05/31/82
01/31/81
09/30/80
09/30/81
09/30/82
09/30/80
09/33/81
10/31/31
09/30/82
09/30/80
09/30/81
05/13/81
05/31/62
09/30/82
09/30/80
09/30/81
09/30/82
05/31/82
09/30/80
09/30/81
STATE
STATE
STATE
STATE
STATE
STATE
SI ATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
30
30
30
30
30
30
30
30
30
09/09/80 IN COMPLIANCE
01/06/81 IN COMPLIANCE
09/25/80 IN COMPLIANCE
05/20/81 IN COMPLIANCE
11/05/79
10/06/80 IN COMPLIANCE
05/15/80 IN COMPLIANCE
05/13/81 IN COMPLIANCt
00/00/00
12/10/60 IN COMPLIANCE
Eltf
05/28/81 IN COMPLIANCE
-------
Z0322
203Z8
20319
L0334
DO
I—•
ro
20340
HERCULES» INC.
2816 3
WESTVrtCO CORP PULP 2611 3
HESTVACO CHEh DIV 2819 3
WALKER MUCHN «= FOUND 3321 3
WAVN-TEX
WEBLITE CORP
3295
08 09/30/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N 30
08 09/30/81 STATE INSPECT'N
08 09/30/83 STATE INSPECT'N 30
08 09/30/81 STATE INSfECT'N
08 '09/30/82 STATE INSPECT'N
08 09/39/61 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N 30
08 39/30/81 STATE INSPECT'N MC
08 09/30/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N
08 09/30/81 STATE INSPECT'N 30
08 01/21/81 STATE INSPECT'N 30
08 06/3(3/81 STATE INSPECT'N
06 09/30/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N 30
08 09/36/81 STATE INSPECT'N 30
08 05/31/82 STATE INSCECT'N
08 09/30/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N
08 09/30/81 STATE INSPECT'N 41
08 07/31/81 STATE INSPECT'N
08 07/31/82 STATE INSPECT'N
07/28/80 IN COMPLIANCE
05/12/80 IN COMPLIANCE
03/26/60 IN COMPLIANCE
05/22/81 IN COMPLIANCE
/ /
00/00/00
10/02/80 IN COMPLIANCE
01/21/81 IN COMPLIANCE
09/19/80 IN COMPLIANCE
05/05/31 IN COMPLIANCE
00/00/00
02/26/81 NOT IN OPEFJATIO
Ell
-------
20341
VIRGINIA LIME CO
3274 3
20342
GEORGIA BONDED FIBER 2200 3
cn
i
20381
LYNCHBURG FOUNDRY
J3£l 3
20391
PANTASOTE
3069 4
08
08
08
08
08
06
08
06
08
08
08
08
08
03
08
08
49
08
08
08
49
06
08
09/30/82
01/05/81
01/31/82
04/14/81
09/30/80
09730/61
04/30/82
01/31/82
09/30/82
09/30/80
09/30/81
05/31/82
09/30/82
03/31/81
01/31/82
89/30/60
09/30/80
09/30/61
09/30/82
09/30/80
09/30/81
09/30/81
09/30/82
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N 30
EPA faVR INSPECT
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N
EPA OVR INSPECT
STATE INSPECT'N 30
STATE INSPECT'N
01/05/81 IN COMPLIANCE
04/14/81 IN COMPLIANCE
01/05/81 IN COMPLIANCE
06/10/80 IN COMPLIANCE
05/22/81 IN COMPLIANCE
01/09/81 IN COMPLIANCE
06/11/80 IN COMPLIANCE
03/25/81 IN COMPLIANCE
00/00/013
12/30/80 IN COMPLIANCE
-------
20397
SHELL OIL COMPANY 5171 3
20412
03
I
£0413
20429
26431
20432
WAYNE MFG.CO.
3442 4
WESTERN STATE HOSf 8061 3
CROMPTON-SHENtNDOAH 2299 3
VA LIMESTONE CORP 1422 9
RADFORD LIMESTONE 1 1422 3
RADFORD LIMESTONE 2 1422 3
08 09/30/80 STATE INSPECT'N 30
08 09/30/61 STATE INSPECT'N
08 09/30/60 STATE INSPECT'N
08 09/30/81 STATE INSPECT'N
08 09/30/82 STATE INSPECT'N
08 ' 09/30/80 STATE INSPECT'N 30
49 09/30/81 EPA OVR INSPECT 10
08 09/30/81 STATE INSPECT'N
08 09/30/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N 30
08 09/30/81 STATE_JNSPECJLr N
08 09/30/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N
08 09/30/81 STATE INSPECT'N
08 09/30/82 STATE INSPECT'N
08 05/31/81 STATE INSPECT'N •
08 09/30/80 STATE INSfECT'N 30
49 09/30/80 EPA OVR INSPECT 30
08 09/30/81 STATE INSPECT'N 10
08 09/30/82 STATE INSPECT'N
08 05/31/81 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N 30
08 09/30/81 STATE INSPECT'N
03/06/80 IN COMPLIANCE
11/27/79 IN COMPLIANCE
68/21/81 OUT OF COrtPLIAN
09/25/80 IN COMPLIANCE
II
I I
I I
I I
I I
I /
06/24/80 IN COMPLIANCE
06/25/80 IN COMPLIANCE
04/28/81 OUT OF COMPL I AN
05/05/80 IN COMPLIANCE
-------
CO
I—"
Ul
20433
20434
Z0435
2P437
204 38
20447
20448
RADFORD LIMESTONE 1446 3
RADFORD LIMESTONE 3 1412 3
RADFORD LIMESTONE 4 14i2 3
HARDWOOD LUMBER CORP Z421 4
TAYLOR RAMSEY 2421 3
WEBSTER BRICK
SOUTHERN STATES COOP 2042 3
49 , 09/30/81
08 09/30/82
08 09/30/80
08 09/30/81
08 09/30/82
08 .07/31/81
03 09/30/80
08 02/09/81
08 05/31/82
08 09/30/82
08 09/30/80
03 09/30/81
03 09/30/8(1
08 05/31/62
08 09/30/80
08 09/30/81
08 09/30/80
49 09/30/81
08 09/30/81
08 09/30/82
08 09/30/80
08 09/30/81
08 09/30/82
EPA OVR INSPECT il 08/26/81
STATE INSPECT'N / /
STATE INSPECT'N 00/00/00
STATE INSPECT'N 30 12/05/80
STATE INSPECT'N / /
STATE INSPECT'N / /
STATE INSPECT'N 30 05/10/80
STATE INSPECT'N 41 02/09/81
STATE INSPECT'N / /
STATE INSPECT'N / /
STATE INSPECT'N 30 05/16/80
STATE INSPECT'N / /
STATE INSPECT'N / /
STATE INSPECT'N / /
STATE INSPECT'N 30 06/16/80
STATE INSPECT'N 30 05/08/81
STATE INSPECT'N 30 10/18/79
EPA OVR INSPECT 30 08/20/81
STATE INSPECT'N / /
STATE INSPLCT'N / /
STATE INSPECT'N 30 06/30/80
STATE INSPECT'N / /
STATE INSPECT'N / /
OC SCHED REQ
IN COMPLIANCE
IN COMPLIANCE
NOT IN OPERATIC
IN COMPLIANCE
IN COMPLIANCE
IN COMPLIANCE
IN COMPLIANCE
IN COMPLIANCE
IN COMPLIANCE
-------
20450
20451
oo
i
CTi
10455
20454,
20457
BLUE RIDGE STONE 1422 3
HARRIS HARDWOOD CO. 2426 3
ALLIED CHEM CORP 2819 9
ROCKYDALE QUARRIES 1422 3
ROCKYDALE QUARRItS 3274 3
20458
JAMES RIV LIMESTONE 3274 3
08 09/30/80
08 09/30/81
06 09/30/82
08 01/13/81
08 06/30/81
06 , 09/30/80
08 09/30/81
08 09/30/82
08 09/30/80
08 09/30/81
08 09/30/82
08 03/31/82
08 09/30/60
49 09/30/81
08 09/30/81
06 09/30/82
08 07/31/81
08 12/31/81
08 09/30/80
08 09/30/81
08 05/31/82
08 09/30/82
08 09/30/80
STAJE INSPECT'N 30
STATE INSPECT'N
STATE INSPLCT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N
STATE INSCECT'N
EPA OVR INSPECT 36
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N 10
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N
04/22/80 IN COMPLIANCE
01/13/81 IN COMPLIANCE
00/00/00
10/02/80 IN COMPLIANCE
00/00/00
02/02/81 IN COMPLIANCE
12/18/80 IN COMPLIANCE
05/12/81 IN COMPLIANCE
12/10/80 OUT OF COMPLIAN
00/00/00
-------
03
20460
2046!
20462
20468
20469
APP POWER-GLEN LYN 4911 3
STATE 'iTONE CORI-'
STATE STONE CORP
NORFOLK & WESTERN
RELIANCE UNIV.
1422 3
1422 4
3743 4
ISM 3
20470
PULASKI FURNITURE 251 1 4
08 09/30/81
08 09/30/82
3 08 09/30/80
08 09/30/81
08 02/28/82
08 01/23/81
08 01/31/81
08 09/30/82
2 08 09/30/60
08 09/30/81
08 09/30/82
1 08 09/30/80
2 08 09/30/81
50 05/22/81
06 04/30/81
08 09/30/82
2 08 09/30/80
08 09/30/81
08 05/13/81
08 05/31/82
08 09/30/82
2 08 10/31/81
08 09/30/80
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N
STATE INSCECT'N 30
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
EPA INSPECTION 30
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
12/10/80 IN COMPLIANCE
05/15/80 IN COMPLIANCE
05/13/81 IN COMPLIANCE
\
i
01/23/81 IN COMPLIANCE
06/12/60 IN COMPLIANCE
10/02/80 IN COMPLIANCE E10
06/03/81 IN COMPLIANCE
00/00/00
10/02/80 IN COMPLIANCE
05/13/81 IN COMPLIANCE
05/20/61 IN COMPLIANCE
-------
L0471
LONE JACK LIMESTONE 1422 3
£3477
VETERANS ADMIN. HOS. 3062 3
20460
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i—>
oo
STANLEf FURNITURE 2511 3
ACCO STONb 1422 3
20484
ADAMS CONST. CO 1422 4
08 09/30/81 STATE INSPECT'N 30
08 05/31/82 STATE INSPECT'N
08 09/30/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N 33
08 09/30/81 STATE INSPECT'N
49 09/30/81 EPA OVR INSPECT 30
08 09/30/82 STATE INSPECT'N
08 02/26/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N 30
08 09/30/81 STATE INSPECT'N 30
08 09/30/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N
08 09/30/81 STATE INSPECT'N 30
08 09/30/82 STATE INSPECT'N
08 11/05/80 STATE INSPECT'N 30
08 09/30/80 STATE INSPECT'N
08 09/30/81 STATE INSPECT'N 30
08 11/31/81 STATE INSPECT'N
08 09/30/82 STATE INSPECT'N
08 10/31/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N
08 09/30/81 STATE INSPECT'N 30
08 04/27/81 STATE INSPECT'N 30
10/13/80 IN COMPLIANCE
05/12/80 IN COMPLIANCE
06/25/80 IN COMPLIANCt
02/22/80 IN COMPLIANCE
02/26/81 IN COMPLIANCE
/ /
00/00/00
10/27/80 IN COMPLIANCE
/ /
11/05/80 IN COMPLIANCE
00/00/00
10/03/80 IN COMPLIANCE
02/09/81 IN COMPLIANCE
04/27/81 IN COMPLIANCE
-------
Z0510
CO
I
VD
20515
20516
1*517
20513
20523
HERCULES
E.I DUPONT
2821 3
ROCKINGHAH'MILLING 2042 4
REYNOLDS METAL CO 2821 3
REEVES BROS VULCAN 3069 3
2614 3
VA. METALCRAFTEKS 3446 3
WELLS FURNITURE CO 2500 4
08
08
08
08
08
08 '
08
08
08
08
03
08
08
08
08
08
08
08
08
08
08
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05/31/81
09/30/82
09/30/80
09/30/81
05/31/82
01/31/82
09/30/89
09/30/81
09/30/82
09/30/80
09/30/81
09/30/82
05/31/82
09/30/80
09/30/81
09/30/82
09/38/80
09/3J/81
09/30/82
09/30/80
09/30/81
09/30/82
09/30/81
STftTE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT 'N
INSPECT'N
INSPLCT'N
INSPECT'N
30
30
30
30
30
30
30
30
30
08/06/80 IN COMPLIANCE
05/19/81 IN COMPLIANCE
01/20/81 IN COMPLIANCE
09/26/30 IN COMPLIANCE
07/29/80 IN COMPLIANCE
05/06/81 IN COMPLIANCE
00/00/013
10/27/80 IN COMPLIANCE
09/25/80 IN COMPLIANCE
01/13/81 IN COMPLIANCE
-------
20526
20529
DO
I
ro
o
20542
20544
20546
Z0553
MERCKeCO.INC.CHEH DV 2834 3
BLPiINC.
KOPPERS CO.
2295 4
GENERAL SHALE PROD. 3251 3
GENERAL ELECTRIC 3622 3
Z.491 3
ETHAN ALLEN INC 2511 3
WAMPLER FOODSiINC. 2042 3
08 06/30/81 STATE INSPECT'N
08 09/30/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N
08 09/50/81 STAT€ INSPECT'N 39
08 09/30/82 STATE INSPECT'N
fc8 0Z/12/82 STATE INSPECT'N
68 09/30/80 STATE INSPECT'N
08 09/30/81 STATE INSPECT'N 30
08 09/39/82 STATE INSPECT'N
08 04/30/82 STATE INSPECT'N
08 09/30/83 STATE INSPECT»N 30
08 09/30/81 STATE INSPECT'N 30
08 09/30/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N 30
08 09/30/81 STATE INSPECT'N
08 09/30/82 STATE INSPECT'N
08 0V/30/80 STATE INSPECT'N 30
08 09/30/81 STATE INSPECT'N
08 09/30/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N 30
08 09/30/81 STATE INSPECT'N
08 09/30/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N 30
00/00/00
10/27/60 IN COMPLIANCE
02/12/81 IN COMPLIANCE
/ /
./ /
03/06/80 IN COMPLIANCE
04/01/81 IN COMPLIANCE
/ /
10/12/79 IN COMPLIANCE
/ /
/ /
11/21/79 IN COMPLIANCE
/ /
/ /
09/26/80 IN COMPLIANCE
/ /
/ /
09/12/80 IN COMPLIANCE
-------
CD
20565
20569
20572
20576
20590
20592
20655
08
08
LUCK QUARRY 1422 4 3 08
08
08
JAMES RIV LIMESTONE 3274 4 3 08
08
08
08
GENERAL ELECTRIC 3479 4 1 08
C * 0 RAILWAY CO. 4000 3 3 08
08
. 08
CATAWEA HOSPITAL 8062 3 2 08
49
08
08
GENERAL ELECTRIC CO. 3622 4 1 08
08
08
RE A MAG. WIRE 3357 3 2 08
08
08
09/30/81
09/30/82
09/30/80
09/30/81
09/30/82
07/31/82
09/33/80
09/30/81
09/30/82
09/30/82
09/30/80
09/30/81
09/30/82
09/33/80
09/30/61
09/33/81
09/30/82
02/27/81
02/28/82
09/33/82
09/30/80
09/30/81
01/31/82
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSfECT'N
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 41
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N
STATE INSPIICT'N
STATE INSPECT'N 30
EPA OVR INSPECT 10
STATE INSPECT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPLCT'N
STATE INSPECT'N
STATE INSPECT'N 30
STATE INSPECT'N 30
STATE INSPECT'N
11/30/79 IN COMPLIANCE
02/25/81 NOT IN OPERATIC
06/17/80 IN COMPLIANCE
10/02/79 IN COMPLIANCE
08/20/81 OUT Or COMPLIAN
02/27/81 IN COMPLIANCE
06/14/80 IN COMPLIANCE
05/08/81 IN COMPLIANCE
-------
20656
CO
I
rv>
r\)
20698
20711
2*735
26*763
RADFORD ARMY AMMO PT 9711 3
VEPCO
4911 3
STAR FOUNDRY PRODUCT 3321 3
MENNEL MILLING CO. 2041 3
GrtLLIMORE PAVING CO 2951 4
WOLVERINE
3293 3
08 09/3B/82 STATE INSPECT'N / /
08 04/03/82 STATE INSPECT'N / /
08 07/31/81 STATE INSPECT'N / /
08 09/30/80 STATE INSPECT'N 30 06/10/80
08 09/30/81 STATE INSPECT'N 13 01/0
-------
20745
WHITE MOTOR
3713 3
20771
QUALITY FEEDSr INC. 2042 4
28786
ROCK1HOHAM POULTRY 2342 3
20789
PULASKI FURNTRE CORP 2511 4
DO
I
IN)
CO
2-3794
STAUNTON LIMESTONE 1422 3
20796
SISiON & RYAN
2331 3
20797
SIE-SON S: RYAN
20828
VA. HOT SPRINGS 7011 3
08
08
08
08
08
08
08
08
08
08
08
08
08
08
08
08
08
08
08
08
08
08
08
09/30/82
09/30/80
09/30/81
09/30/82
09/30/80
• 09/30/81
09/30/82
09/30/80
09/30/81
09/30/82
09/30/80
,09/30/81
09/30/82
09/30/80
09/30/81
09/30/82
09/30/80
09/30/81
09/30/80
09/30/81
09/30/82
09/30/80
09/30/81
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
STATE
INSPECT'N
INSPECT 'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPLCT'N
INSPECT'N
INSPLCT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSF'ECT'N
INSPECT'N
INSPECT'N
INSPECT'N
INSPLCT'N
INSPECT'N
30
30
30
30
30
30
30
30
30
00/00/00
10/08/80 IN COMPLIANCE
09/04/80 IN COMPLIANCE
06/05/80 IN COMPLIANCE
00/00/00
12/29/89 IN COMPLIANCE
03/0i>/80 IN COMPLIANCE
00/00/00
10/08/80 IN COMPLIANCE
00/09/00
10/08/80 IN COMPLIANCE
07/09/80 IN COMPLIANCE
02/04/81 IN COMPLIANCE
-------
2087:5
20878
CO
ro
£0911
L0914
20957
VA LIME CO-FOOTE MIN 3274 4 1
VIRGINIA LIME
3295 9
L.H.SAWYER PAVING CO 2951 3 2
BLACKSBURG SANI AU1H 495Z 3
ADAMS CONSTRUCTION . 2951 4 2
SALEMi CITY
4953 4 2
08 02/28/82 STATE INSPECT»N
08 09/30/82 STATE INSPECT'N
08 01/05/81 STATE INSPECT'N 30
08 01/31/82 STATE INSPECT'N
06 04/14/81 STATE INSPLCT'N 30
08 04730/82 STATE INSPECT'N
08 01/05/81 STATE INSPECT'N 33
08 01/03/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N
08 09/39/81 STATE INSPECT'N
08 09/30/82 STATE INSPECT'N
08 09/30/80 STATE INSPECT'N 30
08 09/30/81 STATE INSPECT'N
08 09/30/82 STATE INSPECT'N
08 09/30/60 STATE INSPECT'N 30
08 09/30/81 STATE INSPECT'N
08 69/30/82 STATE INSPECT'N
08 09/30/81 STATE INSPECT'N 30
08 05/31/82 STATE INSPECT'N
08 09/30/82 STATE INSPECT'N
53 09/30/80 PRELIM ENG REV
53 11/15/80 PRELIH ENG REV
08 09/30/81 STATE INSPECT'N 30
01/05/81 IN COMPLIANCE
04/14/81 IN COMPLIANCE
01/05/81 IN COMPLIANCE
00/00/00
09/18/80 IN COMPLIANCE
09/23/80 IN COMPLIANCE
05/14/81 IN COMPLIANCE
10/17/79
01/06/81
10/28/80 IN COMPLIANCE
E10
-------
00
20971
CO
i
ro
un
20972
20982
20991
20995
ADAI1S CONSTRUCTION
A.N. JOHNSTON
WEST SAND fc GFJAVEL
EXXON
MARATHON OIL
2951 3
2951 4
1422 3
5171 4
5171 3
08
2 08
49
' 08
08
2 08
fiQ
IPO
03
2 08
08
08
2 08
2 08
08
08
05/01/81 TEST UNIT #1 30
06/30/31 TEST UNIT *2
09/30/82 STATE INSPECT'N.
09/30/60 STATE INSPECT'N
09/30/81 EPA QVR INSPECT
09/30/81 STATE INSFECT'N
09/30/82 STATE INSPECT'N
09/30/80 STATE INSPECT'N 30
09/30/81 STATE INSFECT'N
09/33/82 STATE INSPECT'N
09/30/80 STATE INSPECT'N 33
09/30/31 STATE INSPECT'N
09/30/82 STATE INSPECT'N
09/30/81 STATE INSPECT'N
09/30/80 STATE INSPECT'N 30
09/30/81 STATE INSPECT'N 30
05/31/82 STATE INSFECT'N
05/06/81 IN COMPLIANCE
00/00/99
/ /
03/00/00
09/30/80 IN COMPLIANCE
07/25/80 IN COMPLIANCE
02/05/80 IN COMPLIANCE
05/1 2/61 IN COMPLIANCE
TOTAL NUMBER QUICK LOOK REPORT LINES
500
-------
CMST = compliance status
CMST value CMDS description
0 UNKNOWN COMPL STATUS
1 IN VIOL-NO SCHEDULE
2 IN COMPL-SOURCE TEST
3 IN COMPL-INSPECTION
4 IN XOMPL-CERTIFICATN
5 IN VIOL-MEETING SCHD
6 IN VIOL-NOT MTG SCHD
7 IN VIOL-UNK WRT SCHD
8 NO APPLIC STATE REG
9 IN COMPL-SHUT DOWN
Note: If CMST is not any of the above values, "Compl Status unknown" will
appear as the description.
oo ECAT = emission category
i
ro
w 0 unknown
1 <100 ton/yr
2 100 to 1000 ton/yr
3 >1000 ton/yr
4 <25 ton/yr
-------
APPENDIX C
SOURCE INSPECTION REPORT FORM
C-l
-------
SOURCE INSPECTION REPORT
DATE.
SOURCE NAME .
LOCATION
. REGISTRATION NO..
PERSON CONTACTED * TITLE .
TYPE Of VISIT
.YEARLY INSPECTION
. UP-DATE REGISTRATION
. VERIFY COMPLIANCE
. VERIFY CONTROL PROGRAM
. VERIFY PERMIT APPLICATION
. CHECK NEW EQUIPMENT
. VISIBLE EMISSION EVALUATION
. INVESTIGATE COMPLAINT
. CHECK MALFUNCTION
. WITNESS STACK TEST
. DETAILED SURVEY PLANT / PROCESS
. GENERAL WALK-THRU VISIT
. CONSULTATION
. CHECK SERF SCHEDULE
. OTHER (SPECIFY IN COMMENTS)
REGISTRATION REVIEW
PLANT LAYOUT DIAGRAM
E-t
E-I^PG. 2
GENERAL INFORMATION
E-2 FUEL BURNING EQUIPMENT
E-2.PG.2
E-2. PG. 3
E-2. PG. 4
E3
E-;, PG, 2
PROCESSING ANO MANUFACTURING OPERATIONS
E-3. PG. 3
E-3. PG. 4
1-4 REFUSE DISPOSAL ANO INCINERATION
E-S HYDROCARBONS STORAGE TANKS. LOADING RACKS, ETC.
E-5. PG. 2
E-6
GASOLINE SERVICE STATION ANO HANDLING FACILITIES
NO •
CHANGE
TO BE
SUBMITTED
ATTACHED
•USE NR WHEN FORM IS NOT REQUIRED OF SOURCE.
CONTROL PROGRAM (Y N .
CONTROL PROGRAM STATUS
PERMIT IY N I
ESTIMATED COMPLETION DATE .
WERE THERE ANY OTHER CHANGES IN PROGRESS?
WILL THESE CHANGES NEED A PERMIT? Y
DISCUSSED? Y N WERE PERMIT FORMS LEFT WITH CONTACT? Y
.. WAS THE REGULATION CONCERNING PERMIT PROCEDURES
. N ARE ANY EXPANSIONS
OR PROCESS MODIFICATIONS PLANNED?.
ESTIMATED START OATE'_
CONTROL EQUIPMENT IY .
WAS CONTROL EQUIPMENT OPERATING? Y .
.. EFFICIENTLY' Y .
IF NO. WHAT CORRECTIVE MEASURES WERE DISCUSSED?.
SAPCI form 12
14/25/781
C-3
-------
IN-STACK MONITORING EQUIPMENT IY N '
WAS IN-STACX MONITORING EQUIPMENT OPERATING'' Y .
IF YES. WHAT WERE THE FINDINGS?
If NO. EXFLAIN. .
VISIBLE EMISSIONS OBSERVED IY N
DESCRIBE ANY VISIBLE EMISSIONS OBSERVED.
COMPLIANCE STATUS
IN COMFLIANCE NOT IN COMPLIANCE UNKNOWN .
COMMENTS
INSPECTING OFFICER SIGNATURE/ DATE
REGIONAL DIRECTOR SIGNATURE/ DATE
C-4
-------
VIRGINIA STATE AIR POLLUTION CONTROL BOARD
VISIBLE EMISSION EVALUATION RECORD
DATE
COMPANY .
LOCATION
REGISTRATION NO.
EMISSION POINT NAME
OBSERVER
HEIGHT TO DISCHARGE POINT
CERTIFICATION EXPIRATION DATE.
CLOCK TIME:
INITIAL
A.M./P.M. FINAL
A.M./P.M.
VISIBLE EMISSION READINGS
«.
HIM.
0
1
2
3
4
5
6
7
»
9
10
11
12
13
11
15
£
17
M
13
20
n
22
23
24
25
26
27
a
a
0
sots
s
30
e
JlWIHUt
oca IF wuCASf
on.
WT.
(WOT
ML
1
nn.
a
31
32
33
3»
35
36
T>
•s
39
«
-------
OBSFJiVFR ! nfATlOH
DISTANCE TO DISCHARGE
DIRECTION TO DISCHARGE
MCIGHT Of 01SERVAT10N POINT
MEATHP1 CONDIT1QHS
WIND DI SECT I ON
NINO SPEED
AMIENT TEfVERATWC
PLJffg
COLOK
DISTMCE VII1ILI
...iniTiAt
HIAGRAM OF OBSERVER AND CESSION POINT
COMMENTS
OBSERVER SIGNATURE
REGION DIRECTOR SIGNATURE
C-6
-------
APPENDIX D
EXAMPLE OF INSPECTION REPORTS COMPLETED
PRIOR TO THE STUDY
D-l
-------
SOURCE INSPECTION REPORT
DATE.
SOURCE NAME
. REGISTRATION NO
LOCATION .
PERSON CONTACTED • TITLE .
TYPE OF VISIT
TK>N
. UP-DATE REGISTRATION
. VERIFY COMPLIANCE
. VERIPV CONTROL PROGRAM
. VERIFY PERMIT APPLICATION
CHECK Htm IOUIPMENT
»/ VISIBLE EMISSION EVALUATION
INVESTIGATE COMPLAINT
CHECK MALFUNCTION
WITNESS STACK TEST
. DETAILED SURVEY PLANT / PROCESS
. GENERAL WALK-THRU VISIT
. CONSULTATION
. CHECK SERP SCHEDULE
. OTHER (SPECIFY IN COMMENTS)
REGISTRATION REVIEW
PLANT LAYOUT DIAGRAM
El GENERAL INFORMATION
EI.PG 2
E 2 FUEL BURNING EQUIPMENT
E-2.PG.2
E-2. PC S
E-2, PG. 4
€3 PROCESSING AND MANUFACTURING OPERATIONS
E3.PG.2
E-3.PG.3
E3.PG.4
E< HYDROCARBONS STORAGE TANKS. LOADING RACKS. ETC.
E.i.PG.2
E4 GASOLINE SERVICE STATION AND HANDLING FACILITIES
NO •
CHANGE
TO BE
SUBMITTED
ATTACHED
•USE NR WHEN FORM IS NOT REQUIRED OF SOURCE
CONTROL PROGRAM IY N
CONTROL PROGRAM STATUS
PERMIT
(Y V...K
ESTIMATED COMPLETION DATE
.. WERE THERE ANY OTHER CHANGES IN PROGRESS? Y_
WILL THESE CHANGES NEED A PERMIT? V N J
DISCUSSED? Y N J.. WERE PERMIT FORMS LEFT WITH CONTACT? Y
WAS THE REGULATION CONCERNING PERMIT PROCEDURES
ARE ANY EXPANSIONS
OR PROCESS MODIFICATIONS PLANNED?.
ESTIMATED START DATE?
CONTROL EQUIPMENT IY V M
_l
WAS CONTROL EQUIPMENT OPERATING? Y V N EFFICIENTLY? Y
IF NO. WHAT CORRECTIVE MEASURES WERE DISCUSMDlJ^
SAPCB Fermi}
(4/2S/7W
D-3
-------
IN-STACX MONITORING EQUIPMENT (Y N Jt )
WAI IN-ITACK MONITORING EQUIPMENT OPERATING- Y .
If VE1. WHAT Wf ME THE FINDINGS!
IP NO. EXPLAIN
VHHLE lMlt»ION«Qt»iRVtD IV V M
OCtCMItf ANY VISIBLE EMISSION* OWERVED
COMPLIANCE STATUS
IN COMPLIANCE
NOT IN COMPLIANCE .
UNKNOWN.
OOMMENT*
INSPECTING OPFICEP) SIGNATURE/ DATE
REGIONAL DIRECTOR SIGNATURE/ DATE
D-4
-------
DATE.
SOURCE NAM
SOURCE INSPECTION NEKWT
I
LOCATION.
.REGISTRATION*).
TYPE OP* VISIT
UP-OATI REGISTRATION
VERIFY COMPLIANCE
VERIFY CONTROL PROGRAM
VERIFY PERMIT APPLICATION
_ CHICK NEW EQUIPMENT
. VISIBLE EMISSION EVALUATION
. INVESTIGATE COMPLAINT
. CHECK MALFUNCTION
. WITNESS STACK TEST
. DETAILED SURVEY PLANT / PROCESS
. GENERAL WALK-THRU VISIT
. CONSULTATION
. CHICK SERF SCHEDULE
. OTHER (SPECIFY IN COMMENTS)
REGISTRATION REVIEW
PLANT LAYOUT DIAGRAM
P-J „.
GENfRAL INFORMATION
E2
FUEL BURNING EQUIPMENT
E-J.PO.J
E.2.PG.3
1-2. FG. 4
f-3 PROCESSING ANO MANUFACTURINO OPERATIONS
E-3.PG.2
E-3.PG.3
E-3. PQ. 4
t-4
E4
REFUSE DISPOSAL AND INCINERATION
HYDROCARBONS STORAGE TANKS. LOADING RACKS. ETC.
E-B.PQ.5
N
GASOLINE SERVICE STATION ANO HANDLING FACILITIES
NO •
CHANGE
\
\
\
\
1
1
V
\
TO BE
SUBMITTED
ATTACHED
•USE NR WHEN FORM IS NOT REQUIRED OF SOURCE.
CONTROL PROGRAM (Y
CONTROL PROGRAM STATUS
PERMIT (Y N.
ESTIMATED COMPLETION DATE _____
WILL THESE CHANGES NEED A PERMIT? V
DISCUSSED? Y N WERE PERMIT FORMS LEFT WITH CONTACT? Y
OR PROCESS MODIFICATIONS PLANNED?
.. WERE THERE ANY OTHER CHANGES IN PROGRESS? Y.
C-. WAS THE REGULATION CONCERNING PERMIT PROCEDURES
ARE ANY EXPANSIONS
ESTIMATED START DATE?__
CONTROL EQUIPMENT (Y __/_ N I
WAS CONTROL EQUIPMENT OPERATING? Y _!_ N EFFICIENTLY? Y.
IF NO. WHAT CORRECTIVE MEASURES WERE DISCUSSED!
SAPCSFonnl?
M/2S/7SI
D-5
-------
IY M V '
IN-STACK MONITORING EQUIPMENT
WAS IN-STACK MONITORING EQUIPMENT OPERATING r Y .
tf YIS. WHAT WEP - THE FINDINGS!
IP NO. EXPLAIN. .
VI8HLE EMISSIONS OMERVED (Y _J__ N 1
Of SCftHU ANY VISIBLE EMISSIONS "••»•"•" o^-fe- ^ C^<^\W>& t^
COMPLIANCE STATUS
INCOMPLIANCE .". MOT IN COMPLIANCE UNKNOWN.
COMMENTS
D-6
-------
D-7
-------
SOURCE INSPECTION REPORT
DATE.
- s -*/
(OUNCE NAME .
o**j*r*.jtl
. REGISTRATION NO.
LOCATION .
PERSON CONTACTED •) TITLE .
'INSPECTION
. UP-OATE REGISTRATION
. VERIFY COMPLIANCE
. VERIFY CONTROL PROGRAM
. VERIFY PERMIT APPLICATION
. CHECK NEW EQUIPMENT
. VISISLS EMISSION EVALUATION
. INVESTIGATE COMPLAINT
. CHECK MALFUNCTION
.WITNESSSTACK TEST
DETAILED SURVEY PLANT / PROCESS
GENERAL WALK-THRU VISIT
CONSULTATION
CHICK MRP SCHEDULE
OTHER ItnclPV IN COMMENTS)
RICISTRATION REVIEW
PLANT LAYOUT DIAGRAM
E-1 GENERAL IWPORMATKJN
!•! PC 2
1-2 PUEL BURNING EOUIPMCNT
E-2.PG 2
E-2.P0.3
J-J.PS.4
E-] PROCESSING ANO MANUFACTURING OPERATIONS
Ej3. PG. 2
1-3. PG. 3
1-3. PG 4 ,
E-4 REFUSE DISPOSAL ANO INCINERATION
14 HYDROCARBONS STORAGE TANKS. LOADING RACKS. ETC.
E-8. PG. 2
14 GASOLINE SERVICE STATION ANO HANDLING FACIUTIU
NO '
CHANGE
TOM
SUBMITTED
ATTACHED
•USE NR WHEN FORM IS NOT REQUIRED OP SOURCE.
CONTROL PROGRAM IV N *C,,.I
CONTROL PROGRAM STATUS
PERMIT 'V " -f '
ESTIMATED COMPLETION DATE .
. WERE THERE ANY OTHER CHANGES IN PROGRESS? Y.
WILL THESE CHANGES NEED « PERMIT? Y N WAS THE REGULATION CONCERNING PERMIT PROCEDURES
DISCUSSED? Y N WERE PERMIT FORMS LEFT WITH CONTACT? Y N ARE ANY EXPANSIONS
OR PROCESS MODIFICATIONS PLANNED!
ESTIMATED START DATI?_
CONTROL EQUIPMENT
SAPCS Form 12
D-8
-------
IN-ITACK MONITORING EQUIPMENT (Y N '
WAI IN-ITACK MONITORING EQUIPMENT OPERATING r Y N .
IP Yll. WHAT WIRE TNI FINOINOIZ
IP NO. EXPLAIN. .
VllltLI EMIUIONS OUiRVtD 'V S "
OUCMIIC ANY VUIM.E IMIKIONIOUIflVf O
" ' C.
INSPECTING OFFICER SIGNATURE/ DATE
7*
t-r~7:
^'
REGIONAL DIRECTOR SIGNATURE/ DATE
D-9
-------
VIRGINIA STATE Am POLLUTION CONTROL BOARD
VISIBLE EMISSION EVALUATION RECORD
DATE b ~ 0 - C /
COMPANY f/ff-d(t. ~ .** r -,^l',s^.-t ,>\ SZ .
LOCATION ^2^^T3 " .T
^7 /? 7l •/ < V/~
(MISSION POJUJ-JtAME ^^Li.irfV^l^ L> ~LS « {ffai^
OBSERVER /\ i^'tfcJ £ '27?'?t
REGISTRATION NO. t^^ZS^
•t HeifiHT TO DISCHARGE POINT
CERTIFICATION EXPIRATION DATE /£> ~ 3t ~B'
CLOCK TIME!
INITIAL/
: FINAL //
VISIBLE EMISSION READINGS
*
//---"Z
NIL
0
1
:
j
<
5
(
1
1
J
10
u
o
a
»
IS
16
17
11
19
2D
21
22
25
24
25
X
27
a
a
EDO!
0
^f
J <
^7^-
-
j2,f.
-?>'
»'
B
^d J"
-
v>«-
^i"
J^
w-.r
-3^
X
-Z^.'
,5^-
-?r
/£~
-
v^-
-
•6
*'
*->
^-r
^i-T
^6
i >**
-?^
aBxT/mSW
EEf.
m.
OTW
ML
' '/V
NIL
X
n
s
35
»
Z
3S
37
X
X
«
U
^
-------
OIITAHCt TO 01
tlMCTIM TO DIlCNMMt
WttNT Or OtMMVATION MINT
rnmiTiais
KIWI OIMCT10H
WIND into
AMIIUIT TtWtlUTUM
KY cminiiiniis
DKTMKt VllllLE
IHITIAI
XU-r
nlASBAM OP OBSFflVFR AMP EMISSION POINT
o -
COMMENTS
I,\
OBSERVER SIGNATURE
RE610N DIRECTOR SIGNATURE
D-ll
-------
DATE.
•OUNCE INSPECTION RKFORT
SOURCE NAME .
LOCATION
REGISTRATION NO.
FtRION CONTACTED • TITLE .
TYPE OF VISIT
_ UP-DATE REGISTRATION
_ VERIFY COMPLIANCE
_ VERIFY CONTROL PROGRAM
_ VERIFY PERMIT APPLICATION
REGISTRATION REVIEW
. CHECK NtW BQUIPMCNT
. VMISLJ EMISSION EVALUATION
. INVESTIGATE COMPLAINT
. CHECK MALFUNCTION
.WITNESSSTACK TEST
. OCTAILED SURVEY PLANT / PROCESS
. GENERAL WALK-THRU VISIT
. CONSULTATION
. CHICK SERP SCHEDULE
. OTHER (SPECIFY IN COMMENTS)
PLANT LAYOUT DIAGRAM
1.1 GENERAL INFORMATION
E-i P/ WERE PERMIT FORMS LEFT WITH CONTACT? Y N V^ ARE ANY EXPANSIONS
OR PROCESS MODIFICATIONS PLANNED?
ESTIMATED START DATE?-
CONTROL EQUIPMENT IY \J tt t
WAS CONTROL EQUIPMENT OPERATING? Y V N EFFICIENTLY? Y
If NO. WHAT CORRECTIVE MEASURES WERE DISCUSSED!
SAPCS torn 12
D-12
-------
IN.«T ACK MONITOBINQ tQUIPMINT (Y _V_ N - 1
MA* IN4TACK MOMITOniNQ COUIMMNT OMB AT I NO > V
» YU. WHAT WMt THI FINDINGS!
- N JLi_.
IF NO. OCFVAIN. .
t t\s
VI8HLI IMISaiONI OMIHVID 'V \J "
OMCMIU ANY VIWM.C EMI8SIOM OHIMVIO.
COMHIANCt iTATVU
IN COMFLIANCI _!
NOT IN COMWLIANCf .
UNKNOWN.
COMMSNTI
Oinccron SICNATUFJC/ DATS
D-13
-------
D-14
-------
APPENDIX E
AGENDA FOR ROANOKE CLASSROOM INSTRUCTION
E-l
-------
ROANOKE PLANT INSPECTION WORKSHOP
AGENDA
Location: Date:
Thrifty Inn October 13-15, 1981
Roanoke, Virginia
Day & Time Topic Speaker
TUESDAY
8:30 Introduction R. Hawks
9:00 Purpose and Scope R. Hawks
SESSION I. PLANT INSPECTION TECHNIQUES
9:15 Comprehensive Inspection Techniques G. Saunders
9:45 Baseline Assessment and Stack Test
Observation S. Schliesser
10:30 BREAK
10:45 Fans and Ventilation Systems G. Saunders
12:00 LUNCH
SESSION II. EVALUATION OF CONTROL EQUIPMENT
1:00 Mechanicals R. Hawks
3:00 BREAK
3:30 Wet Scrubbers G. Saunders
5:00 ADJOURNMENT
E-3
-------
AGENDA (continued)
Day & Time
WEDNESDAY
8:30
10:00
10:30
11:30
1:00
3:00
3:30
4:30
THURSDAY
Topic
ESP's
BREAK
ESP's (continued)
LUNCH
Fabric Filters
BREAK
Opacity
ADJOURNMENT
Speaker
S. Sen! iesser
S. Schl iesser
R. Hawks
G. Saunders
SESSION III. INDUSTRIAL SOURCE CATEGORIES
8:30 Industrial Boilers G. Saunders
10:00 BREAK
10:30 Cement R. Hawks
12:00 LUNCH
1:00 Kraft Pulp R. Hawks
2:00 Safety
3:00 BREAK
3:30 Test
E-4
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APPENDIX F
WORKSHOP EXAMINATION
F-l
-------
PLANT INSPECTION WORKSHOP EXAMINATION
Baghouses
1) Name the three major components of any baghouse?
2) What are the four major mechanisms of particulate capture on a fiber?
3) What are the three types of baghouses as defined by cleaning method?
4) Name the two types of filter media used in baghouses and describe the
structure.
5) What are the most common problems which interfere with cake release?
6) What are the four mechanisms by which fabrics fail?
F-3
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7) Why are inertia classifiers and precleaners (mechanical collectors)
used in baghouses?
8) Why is insulation required on baghouses serving "hot" sources?
9) At what point on bags do most failures occur? Why?
10) Why is bag tension important in maintaining bag life?
11) What is the optimum compressed air pressure required in a typical pulse
jet baghouse?
12) How can cyclic visible puffs be used to determine bag failure in pulse
jet baghouses?
13) What are the three types of fiber materials commonly used in baghouses?
14) Why is a finish used on fiberglass bags?
F-4
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15) Why do bags lose strength when exposed to high temperature and chemicals?
16) Why are long tube sheet thimbles important in reducing bag failures?
17) Baghouse Problem:
Given: A baghouse contains 400 fiberglass bags which are 6 inches in
diameter and 10 feet long. The design gas volume through the
collector is 12,000 acfm at a pressure drop of 4 in H20. The
baghouse contains two compartments with reverse air cleaning.
a) What is the cloth area in the baghouse?
b) What is the air to cloth ratio at design conditions?
c) If the static pressure drop of the baghouse increases, what happens
to the gas volume?
d) If the static pressure drop of the baghouse decreases, what happens
to the gas volume?
e) What is the maximum temperature at which the baghouse should be
operated?
F-5
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Mechanical Collectors
1) What is the basic collection principal of mechanical collectors?
2) What is the upper inlet velocity limit for a typical simple cyclone?
3) What is the reason for using multiple cyclone tubes?
4) What are the variables that affect multicyclone pressure drop?
5) What are the major pluggage mechanisms in a multicyclone?
6) What is the maximum normal pressure drop for multicyclone?
7) Where is the pressure drop developed in a multicyclone?
8) What is the effect on pressure drop if multicyclone gas volume is
increased?
F-6
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9) What affect does hopper inleakage have on cyclone performance?
10) How does hopper evacuation increase multicyclone efficiency?
11) How often should an internal inspection be conducted on a multicyclone?
12) Where does wear occur in a simple cyclone?
13) Mechanical Collector Problem:
Given: A multicyclone collector has 200 tubes and is operated at a
design gas volume of 75,000 acfm (350 F). The tubes are 6
inches in diameter and have an inlet area of 0.125 ft .
a) What is the theoretical pressure drop of the collector if K = 12.67?
b) What is the gas volume handled by each tube?
c) What is the inlet velocity of each cyclone tube?
d) If the gas volume is increased by 50% (112,500 acfm) what is the
cyclone pressure drop? What is the inlet velocity?
F-7
-------
e) If at the above stated given conditions the collector has an efficiency
of 85%, what happens to the efficiency as pressure drop is increased
(increased gas volume)?
F-8
-------
Scrubbers
1) In the analysis of the performance of a fixed-throat venturi scrubber the
following measurements are performed: gas temperature, inlet and outlet
static pressure at the venturi, gas volume (determined from fan operation
or pitot traverses), and liquid flow rate to the scrubber throat. If
these values are known, circle the key operating parameters that may be
determined.
a) Venturi pressure drop
b) Liquid/gas ratio
c) Throat velocity
d)
2) What are the two major collection mechanisms at work in a venturi
scrubber? Which is the dominant mechanism (please circle)? List the
particle size ranges collected by these mechanisms.
3) Is opacity, or a change in opacity level, generally a good indicator of
venturi scrubber performance?
4) The scrubber is part of an entire set of components including pumps,
fans, and settling pond. What piece of equipment is required to
efficiently collect the particulate other than the scrubber body itself?
5) What two conditions may require the use of a presaturator prior to the
scrubber?
a) High dissolved solids in the scrubber water.
b) Low water temperature.
c) Low gas temperature.
d) Volatile, condensible material in the gas stream.
e) Damage to fabric in the scrubber.
f) High gas temperature.
F-9
-------
6) What is the key parameter that indicates venturi scrubber performance?
7) Does a high suspended solid content contribute to nozzle erosion or
nozzle pluggage (Yes or No)?
8) When a nozzle becomes plugged, does it typically affect water distribution
in the scrubber throat?
9) What affect, if any, does a plugged nozzle have on pressure drop?
10) A decrease in liquid-to-gas ratio (L/G) typically does the following:
a) decrease the efficiency
b) has no effect on performance
c) increases the efficiency
11) Indicate the proper operating range for dissolved solids.
12) If high dissolved solids are suspected as a problem at a high temperature
source and clear make-up water is added to the system to maintain water
volume in the entire system and compensate for evaporation losses, where
should this water be added to minimize problems?
a) at the scrubber throat
b) at the presaturator
c) at the sump
d) at the water fountain in the control room
F-10
-------
13) Does the pressure gauge on the water supply header indicate flow of
water to the scrubber?
14) What is the typical range of throat velocities (in cm/s) used to design
venturi scrubbers?
15) What is the typical range of L/G ratios for venturi scrubber?
16) Is a 2 inch, H20 change of pressure drop more significant in a low
pressure or high pressure venturi?
17) What three changes in operation or design may be incorporated to prevent
scrubber freezing?
18) Should fresh water be used to clean non-cyclonic demisters? Why?
19) What is the maximum velocity acceptable for non-cyclonic demisters?
F-ll
-------
20) What range of turn-down ratio is acceptable for a cyclonic separator
from the design value (express as a percentage of design volume)?
21) Scrubber problem:
A scrubber is used to control a small industrial source. The inlet gas
temperature to a presaturator is 350 F (this is the inlet temperature to
the scrubber). Static pressure at the scrubber inlet is -3.0 inches H20.
The gas passes through the scrubber and the conditions at the scrubber
exit are -28 inches H20 static pressure at 175 F. Water flow to the
scrubber is 300 gal/min and gas flow at the scrubber inlet is 22,000 acfm.
After passing through the scrubber the gas is ducted through a cyclonic
separator with an outlet pressure of -31 inches HaO. Assuming the throat
area is 0.75 ft2 determine the following:
a) Scrubber pressure drop
b) Scrubber throat velocity
c) Scrubber L/G ratio
d) Cyclonic separator AP
e) Is the prosaturator functioning properly?
F-12
-------
Fan
1) What two parameters must be measured to use fan tables?
2) What two parameters are "optional" so that only one of the two are
necessary to complete fan calculations?
3) For any given radial blade fan operating at a constant rpm, what is the
effect of a decrease of static pressure across the fan on gas volume and
horsepower?
4) A decrease in fan rpm causes a shift in fan curve. Does this decrease
go towards or away from the "origin" of the fan curve?
5) Which fan type is most commonly applied to industrial gas moving
applications?
6) A decrease in gas temperature at a fan will (at fixed rpm):
a) increase horsepower requirements
b) decrease horsepower requirements
c) not affect horsepower requirements
7) An increase in gas temperature at fixed rpm will
a) increase measured static pressure
b) decrease measured static pressure
c) not change the measured static pressure
F-13
-------
8) A temperature correction must be applied to correct for gas density
differences between actual density and the density of gas for the fan
table. What is the standardized temperature for most fan tables?
9) Does measured rpm have to be corrected for a) temperature, b) static
pressure, and c) horsepower?
a)
b)
c)
10) Once the volume is obtained from fan tables or a fan curve, must the
volume be corrected back to the measured temperature?
11) Fan Problem:
Given the following information on fan operating parameters calculate the
gas volume moved through a Zurn 229XL open wheel fan. Gas temperature:
440 F, fan speed 1000 rpm, static pressure drop across fan: 7.1 inches
FLO, approximate BMP: 45 hp. Assume altitude is approximately sea level.
a) Gas volume = _, acfm
b) If the fan speed is increased to 1225 rpm what are the new values
for (you may use either from table or fan laws):
a) Gas volume
b) Static pressure
c) Fan BMP
c) Would a 100-hp motor be adequate for this application?
F-14
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F-Factors
1) An F-factor may be developed for each fuel type to determine gas volume
produced upon combustion. Under what conditions (i.e., percent excess
air) is an F-factor determined?
2) What is the formula for determining excess air from oxygen in the stack?
Use this formula to determine the percent excess air for a measurement
of 6.0 percent oxygen.
3) Percent excess air may be determined by either CO^ or 02 measurements.
Uhirh mpasiirprnpnt i<; nrpfprrpri 'anH whv?
Which measurement is preferred and why?
4) A boiler is fed 10,000 Ib of coal/h. The heat content of the coal is
11,750 BTU/lb. Measured oxygen content is 2.5 percent and gas tempera-
ture is 420 F. Under these conditions, what would the expected gas
volume be?
F-15
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ESP
1) What are the two major components within an ESP responsible for charging
and collecting the participate?
2) What are the components which remove participate from the internal
surfaces of the ESP?
3) What is the component that provides power to the ESP?
4) In what section would you expect a space-charge "effect" or corona
quench?
a) Inlet section
b) Middle section
c) Outlet section
5) In what area of the ESP would you expect most of the particulate material
to be collected?
a) Inlet section
b) Middle section
c) Outlet section
6) What conditions would you look for if you suspected secondary power
leakage?
a) Moist insulators
b) Dirty insulators
Cracked insulators
a, b, and c
c)
d)
7) What secondary voltage range would be expected in a high efficiency ESP?
a) 100 to 300 volts
b) 1000 to 1500 volts
c) 10,000 to 12,000 volts
d) 30,000 to 40,000 volts
e) 400,000 to 500,000 volts
F-16
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8) Which of the following typically indicate improved ESP performance?
a) Higher SCA
b) Higher superficial velocity
c) High gas volume
d) More T-R's for greater sectionalization
e) Higher power input
f) ESP aspect ratios greater than 1.0
9) What is the electrical indicator of ESP collection efficiency?
10) What resistivity range provides the best ESP performance?
a) 107 to 108 ohm-cm
b) 108 to 1010 ohm-cm
c) 1011 to 1013 ohm-cm
d) none of the above
11) What is the typical spacing between the collecting plates in an ESP?
a) 9 to 10 inches
b) 4 to 5 inches
c) about 1 foot
d) none of above
12) What section of a well-operated ESP would experience the highest secondary
current level?
a) inlet section
b) middle section
c) outlet section
13) If 20 percent more gas volume is being treated by an ESP with the same
power input level, what is most likely to occur?
a) less emissions
b) more emissions
c) same emissions
14) If a T-R set is not operating, what is the most likely cause of the
problem?
a) insufficient instrumentation
b) wire breakage causing a short
c) high resistivity
d) excessive gas throughput
F-17
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15) ESP Problem
Using the given information calculate values for:
1) superficial gas velocity
2) corona power
3) specific corona power
4) penetration
Given Information
Gas Volume = 900,000 acfm @ 330°F
Cross-sectional Area = 2143 ft2
K = 0.50
T-R set efficiency = 0.70
Primary Current
90
105
125
160
195
Field
1
2
3
4
5
Primary Voltage
340
330
315
290
295
a. Calculate superficial Gas Velocity in ft/min and ft/s,
b. Calculate CORONA POWER in WATTS
c. Calculate SPECIFIC CORONA POWER in WATTS/1000 acfm.
d. Calculate PENETRATION in PERCENT.
F-18
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APPENDIX G
EQUIPMENT CHECK LIST
G-l
-------
EQUIPMENT CHECK-OFF LIST
SOURCE NAME
LOCATION
PN
RO II PERSONNEL INVOLVED
INSTRUMENTS
Camera
BioMarine 02 meter
Og meter calibration gas
Pi tot tube #1 (5/16" x 36")
Pitot tube #2 (5/16" x 36")
S-type pitot tube
Magnehelic set #1 (3 gauges)
Magnehelic set 12 (3 gauges)
.0-2 in. magnehelic gauge
36" manometer '
Dwyer inclined manometer
Fisher velometer
Thermocouple #1
Thermocouple #2
Manometer fluid
Phototachometer
Hand-held tachometer #1
Hand-held tachometer #2
Clamp-on ammeter
Stopwatch
Fyrite test kit
Gastec detector kit
Aerodyne cyclone model
EPA method 6 standards
Dial thermometer'
pH meter
pH paper
Spare pitot tube fittings
Plastic tubing
Water bottles
SAFETY GEAR
BioMarine #1
BioMarine #2
Spare 02 bottles
Gas bottle manifold
MSA #1
MSA #2
3M dust/mist masks
Work gloves
Spare soda-sorb
Spare MSA cartridges
Leak-check ampoules
Hard hats
Safety glasses/goggles
Ear protectors
Safety harness
NIOSH Hazardous Chemicals Handbook
G-3
-------
TOOL KIT
Tool box #1 Phillips screw driver
Tool box 12 Flat screw driver
6-volt lantern . • Brass rods
Flashlight Siphon
Wire brush 50 ft tape measure
Duct tape 12 ft tape measure
Hammer Rope
Adjustable C-wrench Snoop leak detector
Pry bar . Bucket
Extension cord
OFFICE'SUPPLIES
Credentials Scissors
Calling cards Stapler
_Confidential stamp and ink pad Paper clips
Project file documents, Ruler (straight-edge)
" reference books
_ Field note books Clipboards
_ Data sheets Time sheets
_ Paper (lined, plain, graph)1 Expense forms
_ Pens Calculator
_ Pencils Erasures
_ Liquid paper
SHIPPING MATERIALS
_ Foot locker Fiberglass tape
_ Packing materials Address labels
"Fragile" stickers
Equipment packed by:
(signature)
Date:
G-4
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APPENDIX H
RECOMMENDED TARGETING PLAN
H-l
-------
TABLE H-l. TARGETING PLAN FOR REGION II
Company
Adams Construction
Catawba Hospital
General Electric
Koppers
Marathon Oil
Mohawk Rubber
General Shale
Old Virginia Brick
No.
20032
20590
20592
20544
20995
20123
-»
20529
Sources
Painting
Boiler (2)
Grit blast
Shot blast
Bake oven
Creosote
Wood boiler
Boiler (2)
Sawing
Boiler (3)
Mixer
Buffer
Kiln
Screening
Crushing
Sand drying
Kiln (2)
Predryer (2)
Grinding
Inspection
Level
3
2
3
2
0
1
3
2
3
2
0
1
3
2
1
2
0
1
3
2
3
2
1
3
2
1
3
2
1
1
3
2
Frequency/yr
1
1
1 (T)3
3
1
1
1
3
1
2
1
2
1
3
1
2
1
2
1
2
1
2
2
1
2
2
1
3
2
1
1
3
(continued)
H-3
-------
TABLE H-1 (continued)
Company
V.A. Hospital
Salem Incinerator
L.H. Sawyer Paving
Southern State Mill
Shell Oil
Roanoke Foundry
Salem Stone
National Gypsum
(Gold Bond)
Wolverine Fabricating
Virginia Lime
No.
20957
20883
20448
20397
20698
20461
20225
20763
20878
Sources
Boiler (4)
. Incinerator
Process
Boiler
Cupola
Kiln 1
Kiln 2
Kiln 3
Raymond mill (2)
Bulk loading
Incinerator
Boiler
Dryer
Processing
Inspection
Level
1
3
2
3
3
2
2
1
0
3
2
2
3
3
3
3
3
3
1
1
3
2
3
2
Frequency/yr
1
1
3
3
2
2
2
2
1
1
3
2
4
4
4
4
4
1
2
1
1
3
1
3
(continued)
H-4
-------
TABLE H-l (continued)
Company
Virginia Lime
VPI
Adams Construction
Appalachian Power
Celanese Fibers
No.
20341
20124
20033
10460
Sources
Kiln 1
Kiln 2
Kiln 3
Precrusher
Secondary crusher
Boiler 6
Boiler 7
Boiler 8
Boiler 9
Boiler 10
Boiler 6
Boiler 51
Boiler 52
Boiler 7
Gas boiler
Acetate dryer
Conveying
Solvent system
Inspection
Level
3
2
3
2
3
2
2
2
3
1
3
1
3
1
3
1
3
1
3
2
3
3
4
3
4
4
3
1
2
3
2
2
Frequency/yr
1
3
1
3
1
3
3
3
1
1
1
1
1
1
1
1
1
1
1
1
1 (T)a
1 (T)a
1 (T)3
1 (T)9
3
1
3
1
2
3
(continued)
H-5
-------
TABLE H-l (continued)
Company
American Safety Razor
Blakemore Construction
Crompton
DuPont
Elkton Limestone
No.
20189
20039
20413
20517
20018
Sources
Boiler (2)
Wash (3)
Trichloroethylene
still
Degreaser
Coating
Plating
Incinerator
Boiler (5)
Tenter (7)
Singe (3)
Boiler (4)
Boiler (1)
Dryer (4)
Fluidized bed
Evaporator (4)
Heat exchanger (4)
Cat. oxidation (3)
Adipic acid
Unloading and
transfer
Adipic acid bin
Inspection
Level
1
1
2
2
1
3
2
1
3
2
1
2
2
3
2
3
2
1
2
2
2
2
3
2
3
2
2
Frequency/yr
2
2
2
2
2
1
1
2
1
1
1
1
1
1 (T)3
3
1 (T)3
3
2
2
2
2
2
1
1
1
1
3
(continued)
H-6
-------
TABLE H-l (continued)
Company
Elkton Asphalt
Ethan Allen
Farrier Paving
Moore Bros.
Mandy Quarry
Quality Feed
Reynolds Metals
No.
20085
20548
20025
20027
20208
20771
20515
Sources
Boiler
Baghouse (4)
Paint (3)
Boiler
Dryer
Mill
Jaw crusher
Screen
Secondary crusher
Screen
Tertiary crusher
Boiler (2)
Mixing
Pelleting
Coal boiler (2)
Oil boiler (2)
Extruder
Solvent rec.
Inspection
Level
3
2
3
2
3
0
3
2
3
2
1
3
2
3
2
2
2
2
2
2
1
1
1
3
2
1
1
0
Frequency/yr
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
2
2
2
2
2
1
1
1
1
3
2
2
1
(continued)
H-7
-------
TABLE H-l (continued)
Company
Rocco
Rockingham Milling
Rockingham Poultry
Stanley Furniture
Stauton Limestone
No.
20087
20513
20480
20794
Sources
Pellet mill
Hammer mill (3)
Boiler (2)
Boiler
Milling
Pelleting
Boiler (5)
Hammermi 1 1
Pellet coolers
Silos
Wood boiler (2)
Oil boiler
Fuel bin (3)
Wood working (6)
Primary crusher
Cage mill
Screen (4)
Hammer mill (3)
Screen (BH)
Cage mill (BH)
Inspection
Level
1
1
1
1
1
1
1
1
1
1
3
1
1
3
2
3
2
i
2
1
2
1
2
3
2
3
2
3
2
Frequency/yr
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
(continued)
H-8
-------
TABLE H-l (continued)
Company
Merck and Co.
v
Frazier Quarry
Frazier Quarry
Johnson Construction
No.
20524
20005
20919
20912
Sources
Incinerator
Underfeed boiler
(2)
Boiler
Oil boiler
Inspection
Level
1
2
3
2
2
1
Sludge incinerator 3
Process: SC 535
DC 729
D 927
DC 301
CM 201
CV 401
CV 901
DC 101
DC 102
SE 101
SE 102
DC 701
Primary crusher
Silo
Screens
Pug mill
Secondary crusher
Tertiary crusher
Limestone
Primary crusher
Screens
Secondary crusher
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
2
2
3
2
2
2
2
3
2
Frequency/yr
1
1
1
1
2
1
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
1
2
1
2
2
2
2
1
2
(continued)
H-9
-------
TABLE H-l (continued)
Company
M. A. Layman
M. A. Layman
James Madison
Virginia Metal
Wampler Foods
West Sand & Gravel
Western State Hospital
No.
20038
20026
20117
20518
20553
20982
20412
Sources
Coal boiler (2)
Oil boilers
Furnace iron
Furnace bronze
Degreaser
Paint booth
Metal polish
Metal buffing
Boilers
Truck loading
Grinding
Mixing
Pelletizing
Crushing
Screen
Coal boiler (3)
Oil boiler (3)
Incinerator
Inspection
Level
3
2
3
2
3
2
1
3
2
3
2
0
0
1
1
1
2
2
2
2
2
2
3
2
1
1
Frequency/yr
1
2
1
2
1
1
1
1
1
1
1
1
1
1
1
1
2
2
2
2
2
2
1
1
2
2
(continued)
H-10
-------
TABLE H-l (continued)
Company
Lynchburg Foundry
No.
20381
Sources
70 cupola
Ml A mold sand
Ml B shake out
Ml C sand cooler
Ml D sand muller
M2 A blasting
M2 B sand elevator
M3 core grinder
M4 bin vents
9A/9B mullers
36 sand furnace
40 shell cupola
70 special cupola
1-6/7A grinding
7 shake out
8A-D/9A-C sand
muller
10 shot handling
11 shell sand
12 shell loop
Inspection
Level
3
2
3
2
3
2
3
2
3
2
3
2
3
2
3
2
3
2
3
2
3
2
3
2
3
2
3
2
3
2
3
2
3
2
3
2
3
2
Frequency/yr
1
3
1
3
1
3
1
3
1
3
1
3
1
3
1
3
1
3
1
3
1
3
1
3
1
3
1
3
1
3
1
3
1
3
1
3
1
3
(continued)
H-ll
-------
TABLE H-l (continued)
Company
Lynchburg Foundry
(continued)
Sisson & Ryan
Adams Construction
Adams Construction
Barger & Son
Burlington Industry
No.
20796
20037
20036
20116
Sources
36 sand furnace
62A cement mixing
62B/C pipe grinding
64,65 sand silo
91-92 core silos
81 shot blast
M2A blast cleaning
MIA/MID MCF mold-
ing
M2B/M3 sand
elevator
Asphalt plant
Primary crusher
Secondary crusher
Tertiary crusher
Coal boiler (7)
Oil boiler (6)
Tenter (6)
Inspection
Level
3
2
3
2
3
2
3
2
3
2
3
2
3
2
3
2
3
2
3
2
2
2
2
3
2
3
2
1
3
2
1
1
Frequency/yr
1
3
1
3
1
3
1
3
1
3
1
3
1
3
1
3
1
3
1
3
2
2
2
1
1
1
1
2
1
3
3
4
(continued)
H-12
-------
TABLE H-l (continued)
Company
C&O R.R.
City of Covington
Lane Jack Quarry
Lone Jack Limestone
Pantasote
Rea Wire
Reeves Bros.
Taylor Ramsey
No.
20576
20119
20471
20021
20655
10516
20438
Sources
Primary crusher
Secondary crusher
Cage mill
Screen
Boiler (3)
Mixer
Pelletizer
Buffing
Enameling (2)
Plasimica
SICME
Boiler (4)
Spreader
Dusting
Wood boiler (2)
Oil boiler (2)
Inspection
Level
3
2
2
2
2
3
2
2
3
2
1
3
2
3
2
2
1
3
2
3
2
3
2
1
1
3
3
2
3
2
Frequency/yr
1
3
2
2
2
1
1
2
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
(continued)
H-13
-------
TABLE H-l (continued)
Company
VEPCO
Weblite Corp.
Webster Brick
General Shale
Georgia Bonded
Hermitite Corp.
James River Lime
James River Lime
James River Lime
Virginia Hot Springs
No.
20675
20340
20447
20529
20342
20077
20459
20320
20569
20828
Sources
Grinding
Kiln (2)
Color
Sand
Kiln
Coal boiler (3)
Boiler
Printing
Mills
Storage
Crusher
Mills
Bagging
Raymond mill
Boiler (3)
Inspection
Level
1
3
2
3
2
1
3
2
3
2
1
3
2
1
0
3
2
3
2
3
2
3
2
3
2
3
2
3
2
Frequency/yr
1
1
3
1
1
2
1
1
1
1
2
1
1
1
1
1
3
1
3
1
3
1
3
1
3
1
3
1
3
(continued)
H-14
-------
TABLE H-l (continued)
Company
Blue Ridge Stone
Bond Cote
ACCO Stone
Blacksburg Incinerator
Burlington Industry
Coleman Furniture
Cupp Black Top
Exxon
Gallimore Paving
Harris Hardwood
No.
20526
20484
20911
20271
20300
20022
20991
20451
Sources
Primary crusher
Secondary crusher
Sand screen
Lime
Oven
Fines crusher
Screen
Coal boiler
Oil boiler
Tenter (10)
Boiler
Cyclones
Boiler (3)
Cyclones
Inspection
Level
2
2
3
2
3
2
1
3
2
3
2
3
2
3
2
2
1
3
2
2
3
2
0
3
2
3
2
2
Frequency/yr
2
2
1
1
1
1
2
1
2
1
2
1
1
1
1
2
2
1
3
4
1
1
1
1
1
1
3
2
(continued)
H-15
-------
TABLE H-1 (continued)
Company
Hercules
Hercules
Hoover Color
Reliance Universal
Lonestar
No.
20510
20322
20321
20469
Sources
Boiler
Melt spin (4)
Film extrusion
Melt (7)
Iron dryer (2)
Packer
Lime
Housekeeping
Boiler
Calcining
Mill
Storage
Kiln 1
Kiln 2
Kiln 3
Kiln 4
Kiln 5
Inspection
Level
1
3
2
3
2
3
2
3
2
3
2
3
2
3
2
1
3
2
3
2
3
2
1
3
4
3
4
4
3
4
3
4
3
Frequency/yr
2
1
1
1
1
1
1
1
3
1
3
1
3
1
3
3
1
3
1
3
1
3
1
3 ,
1 (T)a
3
1 (T)3
1 (T)3
3
1 (T)a
3
1 (T)a
3
(continued)
H-16
-------
TABLE H-l (continued)
Company
Lonestar (continued)
Singer Furniture
Roanoke Electric
Radford Limestone
Radford Limestone
No.
20131
20431
20433
Sources
Primary crusher
Cone crusher
Raw mill
Finish mill (9)
Cooler (4)
Packing (6)
Finish silo (10)
Miscellaneous
baghouses
Boiler
Sanding
Cyclones
Painting, etc.
Furnace 2
Furnace 3
Furnace 4
Primary crusher
Secondary crusher
Primary crusher
Secondary crusher
Tertiary crusher
Fines
Inspection
Level
3
2
3
2
3
4
3
3
3
2
3
2
3
2
3
2
3
2
2
0
3
2
3
2
3
2
2
2
2
2
2
2
Frequency/yr
1
3
1
3
1 (T)a
4
4
1
3
1
3
1
3
1
3
1
3
4
1
1
3
1
3
1
3
2
2
2
2
2
2
(continued)
H-17
-------
TABLE H-l (continued)
Company
Radford Limestone
Westvaco
Westvaco
No.
20433
20328
Sources
Primary crusher
Secondary crusher
Tertiary crusher
Regenerator
Devolatilizing kiln
Carbon incinerator
Coal prep.
Granular prep.
Granular finishing
Fluid bed oxidizer
Kiln scrubbers 1
and 2
Kiln 1
Granular storage,
screening,
grinding, and
powder carbon
storage
Bulk conveying,
packaging
Boiler 6
Boiler 7
Boiler 8
Boiler 9
Lime kiln
Calciner
Recovery boiler 1
Slakers (3)
Inspection
Level
2
2
2
3
3
3
2
3
3
3
3
3
3
3
3
3
4
3
4
3
4
4
3
4
3
4
3
4
3
2
Frequency/yr
2
2
2
4
4
1
3
4
4
4
4
4
4
4
4
3 a
1 (T)a
3 .
1 (T)a
3 ,
1 (T)3
1 (T)3
4
1 (T)3
3
1 (T)a
3
1 (T)a
3
4
(continued)
H-18
-------
TABLE H-l (continued)
Company
Westvaco (continued)
Mennel Milling
Walker Machine
Rockydal Quarry
S.R. Draper Paving
Virginia Asphalt
Wells Furniture
N&W Railroad
No.
20711
20334
20457
20035
20031
20523
20468
Sources
Smelt tanks (2)
.Blow tanks,
relief
accumulators
Boiler
Silos (5)
Shot
Sand reclaim
Furnaces
Crushing
Loading
Boiler
Cyclones
Boiler 3
Electric arc
Sand shake-out
Shot blast
Inspection
Type
2
2
1
3
2
3
2
3
2
1
3
2
3
2
3
2
3
2
3
2
2
3
2
3
2
3
2
3
2
Frequency/yr
4
2
1
1
1
1
3
1
3
4
1
3
1
3
1
1
1
1
1
1
2
1
2
1
2
1
2
1
2
(continued)
H-19
-------
TABLE H-1 (continued)
Company
Pulsaki Furniture
Pulsaki Furniture
No.
20470
20789
Sources
Sanders
Cyclone
Boiler
Boiler (3)
Machine room
Paint booths
Machining finish
Waste storage
Cyclones
Inspection
Level
3
2
2
3
2
3
2
3
2
0
3
2
3
2
2
Frequency/yr
1
2
3
1
2
1
2
1
2
1
1
2
1
2
2
(T) = stack test recommended.
H-20
-------
APPENDIX I
EXAMPLE OF INSPECTION REPORTS PREPARED AS A
RESULT OF IMPLEMETING MODIFIED INSPECTION PLAN
1-1
-------
Example No. 1
An internal inspection of this gray iron cupola fabric filter was performed
on this unit after an initial inspection of the unit revealed no static pressure
was developing across the filter. When the plant manager and 1 entered the
fabric filter, we were both amazed at the conditions that we found.
The following is a list of problems that we found in the unit:
1. Bags had holes in them.
2. Bags that had been replaced had simply been cut off and die new bag had
been inserted in the old bag mount.
3. Bag shaker motors had been ranoved.
4. Water was leaking in the roof and sides of the baghouse.
5. Bags were not properly tensioned.
6. Manometers was broken.
7. Wet cyclone sprays were not operating allowing baghouse temperatures to
reach 500°+F.
8. Emergency bypass system was welded shut so that the bag gases could
not be bypassed.
As a result of this inspection, the plant called in a consultant to varify
our findings. The consultant agreed with our findings and estimated the cost of
repairs in excess of $25,000. At that time, company officials explained the
company's current financial condition explaining that they were in bankruptcy
and could not afford to maintain the unit. They also stated that if they were
allowed some time, that they would replace the cupola with an electric furnace.
As a result, the company applied for and received a variance of our opacity
standards until January 1983, when they are to have electric furnaces installed.
Today, repairs on the cupola have been completed that allow the unit to
operate within our opacity standard until the new electric furnaces are installed.
1-3
-------
Example No. 2
During my first inspection at this source, I inspected both fabric filters
handling emissions from three electric arc furnaces. The first fabric filter
handling emissions from the number two and three furnaces was found to have
several problems. They were:
1. Bags that had fallen from their mounts.
2. Hoppers that had overfilled causing bags to plug.
3. Improperly sealed bags.
4. Manometers that were not operating
5. Improperly calibrated amp and temperature readings.
6. Extremely low flow rates to the fabric filter.
These problem were reported to plant officials and corrective action was
taken. Inspections performed on this fabric filter since that time have cited
improved maintenance practices, but occasional problems still occur that our
inspections find allowing the source to start corrective action. •
The second fabric filter is handling emissions from the nunber four furnace
and roof canopys. This fabric filter is also equipped with a multalclone precleaner
that was designed to knock out larger particles to prevent bag damage. When I first
inspected this control device, I found a 12 inch pressure drop across the multaclone,
I investigated further found that the hoppers on this sytern were plugged and that th<
air lock was frozen. During that inspection we found that the baghouse was
being well maintained and that amp and temperature reading being recorded by the
company's instruments were fairly accurate.
We did however report to the source that a problem existed with the multaclone
and we felt that corrective action should be taken.
During my next visit to the source, I found that the pressure drop across the
multaclone had returned to normal conditions as designed. The only problem I found
with the system, was that water was leaking in one of the bag compartments. At
that inspection, this plant was listed as in compliance. The next inspection
revealed that almost no pressure drop was occuring across the multaclone and
problems had began to occur in the baghouse. Problems included:
1 . bag seal leaks
2. holes in bags
3. bags loose from mounts
1-4
-------
Example No. 2
Further investigation by our staff revealed that three rows of tubes in
the tnultaclone had been removed and that many other tubes were to be removed.
The source was cautioned at that time that while the multaclone was not considered
a vital piece of control equipment, we felt that failure to maintain it would
result in more maintenance on the number four filter. Since that time, the
company has continued to remove multaclone tubes and maintenance on the number
four filter has increased. We are now carefully observing this system and
advising the company that no leniency will be given should the unit be found
out of compliance.
1-5
-------
APPENDIX J
LETTERS FROM INDUSTRY
J-l
-------
JAMES RIVER LIMESTONE COMPANY, INC
DOLOMITIC AND HIQM CALCIUM LIMHTONI
November 27> 1981 -
-------
COMMONWEALTH of VIRQINIA
State Air Pollution Control Board
INTRA-AGENCY MEMORANDUM
TO : FT.lea
FROM : Chemist, Region II
SUBJECT : National Gypsum (Baghouse: Maintenance)
DATE : January 26, 1982
During the visit to National Gypsum Co. on 1-25-82, Mr. T. Hayman
informed me that there was a problem with their bag suppliers meeting
specifications.
He.was surprised that the reason why bags were being installed
upside down was because suppliers had the rings sewed into the wrong
end. Again, he thanked our and FEDCO's efforts for bringing this to
their attention.
Unfortunately, they have many suppliers, and do not know which firm
makeaxhe error, however, they are beginning to inspect every shipment
from this day forth, and will have the problem remedied.
1. bags for the baghouse
2. proper maintenance aid operating procedures
RCM/vlc
J-4
SAPCB Form 15 (7/79)
-------
, Gold Bond
Building
'Products
January 28, 1982
Mr. Donald L. Shepherd
Director, Region II
State Air Pollution Control Board
Commonwealth of Virginia
5338 Feteri Creek Road
Roanoke, Virginia 24019
Dear Mr. Shepherd:
We wish to express our thoughts on the activities of the State
Air Pollution Control Board at Kimballton over the last few
months.
Mr. Rick-Moore, Chemist Region II, SAPCB has been working with
Kimballton plant personnel towards improving our dust collection
performance.
We have concentrated our efforts toward No. 3 kiln fiberglass
bag house performance.
The objective is two fold: •-,,
a. to improve the day to day performance
b. to make more cost effective the existing collection
equipment.
As a result of this program it was discovered that some glass bags
were incorrectly installed, ic. upside down. Further investigation
revealed this Improper installation was due to the glass bag
supplier fabricating the bottom ring of the individual bags in the
top position rather than the bottom position just above the 12"
cuff.
Baghouse inspection also showed evidence of workers abrading the
bags with tools they apparently carry in their pockets during
installation work.
These two examples are illustrated to highlight the value of
SAPCB's program to a plant operating dust collecting equipment.
These are simple items but they shorten bag life.
J-5
-------
Mr. D. L. Shepherd Page 2
Several other items are under investigation; such as, dust
buildup around tube sheet timbles, method of tieing off failed
bags, corrosion scale abrading bags. These are under consider-
ation for corrective action*
It is our interest and objective to maximize the performance of
the dust collection equipment at Kimballton. Better performance
means cleaner air and secondly, we see an economic benefit of
reduced maintenance cost.
We subscribe to the SAPCB's program and look forward to our
continuing good relations.
Sincerely,
GOLD BOND BUILDING PRODUCTS
Division of National Gypsum Co.
R. Haymarv
Plant Manager
TRH/pc
cc: Mr. Robert J. Friedheim
Director - Environmental & Operating Services
Gold Bond Building Products
2001 Rexford Road
Charlotte, N. C. 28211
J-6
-------
APPENDIX K
SUMMARY OF CHANGES IN INSPECTION PROCEDURES
AS A RESULT OF THE STUDY
K-l
-------
SUMMARY OF PAST AND PRESENT INSPECTION PROCEDURES BY SOURCE
Source GG. Past-recorded visible emissions and available gravel bed filter
operating parameters; Present-measure additional parameters such as 02 to
determine inleakage, and include internal inspections.
Source EE. Past-recorded ESP electrical characterisitcs; Present-analyzing
these data plus internal inspection.
Source II. Past-opacity; Present-all boiler parameters and internal inspec-
tion.
Source FF. Past-opacity; Present-all boiler and ESP parameters, plus internal
inspection.
Source Q. Past-opacity; Present-baghouse parameters plus internal inspec-
tion.
Source 0. Past-opacity; Present-baghouse parameters plus internal inspec-
tion and Ap.
Source P. Past-opacity. Present-boiler and baghouse parameters plus internal
inspection.
Source G. Past-opacity and ESP parameters; Present-better interpretation of
ESP parameters plus internal inspection of ESP's and baghouses.
Source V. Past-opacity and ESP parameters; Present-better interpretation of
ESP parameters plus internal inspection of ESP's and multiclones.
Source S. Past-opacity; Present-boiler parameters plus internal inspection
of baghouse and Ap.
Source L. Past-opacity; Present-internal baghouse inspection plus Ap.
Source J. Past-opacity; Present-boiler parameters.
Source H. Past-opacity; Present-internal baghouse inspection plus Ap.
Source B. Past-opacity; Present-internal baghouse inspection plus Ap.
Source! BB. Past-opacity; Present-boiler parameters.
Source X. Past-opacity; Present-internal boiler inspection plus Ap.
Source Z. Past-opacity; Present-boiler parameters.
Source CC. Past-opacity; Present-boiler parameters.
K-3
-------
Source E - Process 1. Past-opacity and scrubber temperature and Ap; Present-
better understanding of operation plus internal inspection of baghouses.
Source E - Process 2. Past-opacity and ESP data; Present-scrubber and boiler
parameters and internal inspections of boilers and ESP's.
Source U. Past-opacity; Present-internal inspection of scrubbers and bag-
houses.
Source JJ. Past-opacity; Present-baghouse parameters plus internal inspec-
tion.
Source F. Past-opacity; Present-boiler parameters plus internal inspection
of multiclone.
Source M. Past-opacity; Present-boiler and baghouse parameters plus internal
inspection.
Source N. Past-opacity; Present-boiler and baghouse parameters plus internal
inspection.
K-4
-------
APPENDIX L
LETTERS FROM REGIONAL DIRECTOR AND DIRECTOR
OF COMPLIANCE
L-l
-------
ELIZABETH H HASKELL. CHAIRMAN • jp
MARTINSVILLE «*
CARL C REDINGER. VICE CHAIRMAN Jj
ALEXANDRIA '"" '
EDGAR B BOYNTON
RICHMOND
AXEL T MATTSON
COMMONWEALTH of VIRGINIA
WALLACE E REED e A • n /; • r* i r> i DONALD L SHEPHER
•state Air Pollution Control Board REGIONAL"DIRECTO
CHARLOTTESVILLE
Valley of Virginia Regional Office
SUITE A. EXECUTIVE OFFICE PARK
5338 PETERS CREEK ROAD
HOANOKE. VIRGINIA 24019
PHONE (703) 982-7328
October 22, 1982
Mr. Ronald L. Hawks
PEDCo Environmental, Inc.
505 South Duke St.
Suite 503
Durham, NC 27701
Dear Ron:
Enclosed are summaries of preliminary results of your source inspection
training program. Even though we have only begun to utilize the potential
of these techniques, the results have been dramatic.
At this stage we have primaafy investigated existing control equipment,
since we believe that the great majority of our sources already have all
the control equipment necessary for compliance. Even though you had warned
us to expect problems with the majority of our control equipment, we have
been surprised at the widespread extent of these problems, and so has
industry. At a recent staff meeting our"gut" estimate was that about 80%
of the control of the control equipment we have inspected has some problem
that could eventually lead to non-compliance.
With one exception the industries where we have used the
advance inspection techniques have been receptive. Typically, an industry
is first skeptical, believing that their control equipment is operating
as well as it can. Their next reaction is usually shock or embarrassment
when developing problems are pointed out. Finally, thQrwill express their
gratitude for being shown the problem before it becomes worse; at this
point most resolve to repair the problem and/or improve their maintenance
programs. In general, by demonstrating an increased knowledge and interest
on our part, we also gain increased respect from the industry. By empha-
sizing the cooperative, noopunitive approach, we have minimized any sense
by industry that they are being unduly harassed.
Our next step in utilizing this training is to identify sources where
existing controls, no matter how well maintained and operated, are simply
not adequate.
L-3
-------
Mr. Ron Hawks
PEDCo 10-22-82
Page 2...
Along with the training we have also revised our plan for scheduling
inspections. This plan (attached) is aimed at putting more emphasis on
our more serious problem sources, or those sources with the greatest
potential to cause a problem. To accomodate the increased time required
to make an in-depth inspection, the total number of major source inspect-
ions has been reduced. However, we believe that this loss in quantity
will be more offset by gains in quality of inspections.
In the near future , I also plan to improve our reporting and record-
keeping system such that our inspection reports will be more meaningful
and our files more useful.
In summation, although this training has not; resulted in a rash of
citations or massive investment in control equipment, it has improved
our understanding of how control equipment works in the real world. If
anything, it has also improved our relations with most industries, since
they now see us more as partners in the continuing effort to insure that
their costly investments in pollution controls actually produce the cleaner
air that we have all paid for.
Quite simply, in my 10^ years in air pollution control, this is the
most valuable training I have received.
Sincerely,
Donald L. Shepherd
Director, Region II
P.S. My only criticism is that we are still awaiting your reports of
your inspections.
cc: Executive Director
Director, Division of Compliance
L-4
-------
CMP-OytJ-82
E. FOLGCR TAYLOR,CHAIRMAN
S1AUNTON
ELIZABETH H. HASKELL. VICE CHAIRMAN
MARTINSVILLE
COMMONWEALTH of VIRQINIA
Air Pollution Control Board W.R.MEYE
YORKTOWN ROOM UOG. NINTH STREET OFFICE BUILDING EXECUTIVE DIRECTO
RICHMOND. VIRGINIA 73719
CARL C. REOINGER TELEPHONE. (8041 786-2378
ALEXANDRIA
March 17, 1982
Mr. Abraham Ferdas
Chief, General Enforcement Section
U.S. EPA - Region III
6t,h & Walnut Streets
Philadelphia, PA 19106
Dear Abe,
Yesterday the field portion of our inspector training was started
in our Regions III and V. As you know Ron Hawks, Gary Saunders and others
from PedCo conducted the academic training for 6 of our 7 regions in
December. Gary and Ron are performing the field training as they did
with the pilot program in our Region II last fall.
So far the training has proved to be most beneficial. The academic
training was very concentrated and many of our people have spent considerable
time since the formal instruction in expanding their knowledge of various
types of control equipment. All of the regional people are lookin;} forward
to the field training because of the fine reports coming from Don Shepherd
in our Region II Office. The Region II inspectors have experienced quite
a bit of success in working with industry on improving the maintenance
and operation of its air pollution control equipment.
We expect that the success enjoyed by our Region II staff in conducting
technical inspections will be repeated in the other regions with a resulting
improvement in the operation of control equipment throughout the state.
The methods being taught by PedCo of inspecting and providing assistance
to industry fit Virginia's style of enforcement activity so that the air
will be cleaner and the SAPCB image will be enhanced simultaneously.
Abe we particularly appreciate the support of the EPA, Region III
staff with this training venture. Your assistance has proved to be
invaluable in giving our continuous compliance program a good start.
Best personal regards,
Wirti-amM. Jewell, Jr.
Director, Division of Compliance
L-5
-------
APPENDIX M
SELECTED CASE HISTORIES
M-l
-------
CASE HISTORY PLANT G
Plant G operates a major portland cement facility that includes kilns,
clinker coolers, raw grinding mills, and associated handling equipment. The
kilns are controlled by ESP's, the clinker coolers by fabric filters, and the
raw mill by an ESP.
A Level 3 inspection of the four ESP's serving Kilns 1 through 4 indicated
that the gas volumes being handled were very high because of ambient air in-
leakage between kiln and collector. The design gas volume is about 190,000
acfm at 500 F. During the inspection, the gas volume was estimated to be ap-
proximately 350,000 to 400,000 acfm. The flue gas oxygen was between 9 and
14 percent at kiln inlet and between 1 and 3 percent at the exit.
As a result of the inleakage and high superficial velocities, the ESP
efficiency was reduced. The opacity of the kiln emissions has exceeded 20
percent and the corona power is generally low. The plant has rebuilt the
evaporative coolers between the kiln and ESP to reduce inleakage, and the gas
volume has been reduced. Internal inspections of the ESP's indicated distri-
bution screen pluggage and gas maldistribution. These have been corrected
through improved rapping.
A Level 3 inspection was conducted on the clinker cooler fabric filter
serving Kilns 1 through 4. An internal inspection indicated clean-side par-
ticulate penetration as a result of gasket failure between the venturi and
the tube sheet. The gaskets are made of a rubber-based material that can
operate at temperatures less than 350°F. Temperatures in the filter have
often exceeded 400°F because no fail-safe high-temperature alarms are used.
Replacement of the tube sheet was required because of abrasive damage around
the gasket seat. Corrections have been made to one of the four collectors and
the others are being corrected.
A Level 3 inspection was conducted on the ESP serving the raw mill and
Kiln 5. The corona power to the unit was lower than normal (i.e., 30%
M-3
-------
of the normal value). Discussions with the plant and further investigations
indicated that the evaporative cooling water pumps serving the unit were out
of service and had been out for an extended period of time. This water
failure resulted in a high resistivity condition in the ESP, which lowered the
corona power that could be delivered to the collector and reduced ESP per-
formance. Normal secondary currents in the last field are about 1500 mA, but
they were reduced to approximately 70 mA during periods of high resistivity.
The plant agreed to replace the defective pumps and to restore the unit to its
proper operating levels.
M-4
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CASE HISTORY PLANT Q
Plant Q operates three electric arc furnaces, which are controlled by
fabric filters. Furnaces 2 and 3 are controlled by side-draft hoods that
are vented to an eight-compartment, shaker-type fabric filter. The filter has
a cloth area of 67,600 ft and a design gas volume of 163,500 acfm at 275°F.
2
The design air-to-cloth ratio is 2.4 acfm/ft . During a Level 3 inspection
it was determined that isolation dampers between inlet plenum and several
compartments were not functioning and that the bags were not being cleaned.
The pressure drop across the fabric filter was quite high (>7.0 in. HLO) and
as a result, several bags had dropped because of the heavy weight of the dust
cake.
It was also noted that the electric arc furnace filter had to be bypassed
or the furnace shut down to effect filter shaking. During subsequent inspec-
tions it was noted that the filter hoppers were being used for storage.
Because the hopper was not insulated, bridging frequently occurred. This
allowed the hoppers to overfill and block a portion of the filter area from
service. As a result of these findings, the plant has corrected the deficiencies
in the dampers, hoppers, temperature instruments, and manometers. These cor-
rections have improved the side-draft hood capture and reduced the fugitive
emissions. Maintenance requirements on the filter have been reduced as a
result of improved bag cleaning and reduced hopper bridging.
Furnace 3 is controlled by a fabric filter, which is preceded by a multi-
cyclone. The ventilation system consists of a fourth hole furnace evacuation
system and a canopy hood. The canopy hood is used during tapping and charging.
Fabric Filter 3 has 11 compartments with a total cloth area of 60,830
2
ft . At a design flue gas volume of 157,000 acfm, the filter has an air-to-
cloth ratio of 2.5 acfm/ft2.
During a Level 3 inspection the gas volume being handled from the hoods
was calculated to be 97,000 acfm, which was 40 percent less than design values,
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and fugitive emissions were observed from the shop area. Further investiga-
tions indicated that the multicyclone pressure drop was 7.0 in. tiJQ, which was
much higher than the design value of 2.0 in. H20. It was determined that the
multicyclone hopper was plugged and the system had not been emptied in 6
months.
The company has corrected the multicyclone hopper problem, and the gas
flow has been increased to about 187,000 acfm. To further increase the hood
capture, the plant has removed the multicyclone tubes. This has increased the
bag failure rate in the filter because of increased abrasion. Thus, the re-
moval of the multicyclone has not been a viable alternative for improving the
overall capture efficiency.
Visible emission violations have been documented during periods of poor
hood performance, and the source has been issued an NOV to correct the prob-
lems with the ventilation system.
Complaints from neighbors in the area have been correlated with excess
emission periods, and in one case, an ambient violation of the 24-hour total
suspended particulate standard was recorded at an adjacent monitor.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 2.
4. TITLE AND SUBTITLE
Development of Pilot Inspection System for Virginia
Air Pollution Control Board
7. AUTHOR(S)
Ronald L., Hawks
David R. Dunbar
9. PERFORMING ORGANIZATION NAME AND ADDRESS
PEDCo Environmental, Inc.
505 South Duke Street, Suite 503
Durham, North Carolina 27701
12. SPONSORING AGENCY NAME AND AQORESS
U.S. Environmental Protection Agency
Stationary Source Compliance Division
401 M Street, S.W.
Washington, D.C. 20460
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
April 1983
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-01-6310
Work Assignment No. 28
13. TYPE OF REPORT AND PERIOD COVERED
Final Report
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES ~
EPA Project Officer for this report was Mr. Gerald Lappan
The purpose of this study was fourfold: 1) to evaluate the inspection procedures
currently used by the Commonwealth of Virginia in the Region II Office, 2) to train the
inspectors in the use of comprehensive inspection techniques, 3) to develop a modified
inspection plan for the Region II area, and 4) to analyze the effectiveness of the
modified inspection plan with respect to improving continued compliance of the sources
located within Region II.
This study was divided into seven major subtasks: 1) evaluation of the current
inspection procedures, 2) development of targeting criteria for selecting the sources
to be inspected and the
in the use of comprehensive inspection techniques, 4) field training of inspectors to
instruct them in the use of field equipment and the techniques covered in the class-
room, 5) development and implementation of a modified inspection plan for Region II,
6) analysis of the modified inspection plan, and 7) preparation of a report describing
the study; presenting the methodology, results, and conclusions; and setting forth
specific recommendations regarding the application of the methodology to other areas i
the Commonwealth of Virginia.
n
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
q
Operation and Maintenance
Continuing Compliance
Inspections
iTEMENT
19. SECURITY CLASS (This Report!
Unclassified
21. NO. OF PAGES
180
Unlimi ted
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (R«v. 4-77) PREVIOUS EDITION is OBSOLETE
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