NORTH CAROLINA DIVISION OF
AIR QUALITY

Inspection Report
Date:  02/16/2017
Winston-Salem Regional Office
MillerCoors LLC - Eden Brewery
NC Facility ID  7900090
County/FIPS: Rockingham/157
Facility Data
MillerCoors LLC - Eden Brewery
863 East Meadow Road
Eden, NC       27288
Lat: 36d 31.1333m     Long: 79d 42.9500m 
SIC:  2082 / Malt Beverages
NAICS:  31212 / Breweries

Permit Data
Permit     03116 / R24
Issued     10/26/2015
Expires   9/30/2023
Classification  Synthetic Minor
Permit Status  Active
Current Permit Application(s) None

                             Program Applicability
                                       
SIP / 112r 
MACT Part 63:  Subpart 6C, Subpart ZZZZ 
NSPS:  Subpart IIII 

Contact Data

Facility Contact
Michael Lozano
Unit Manager-Utilities &WWTP
(336) 627-2502
Authorized Contact
Yves Owens
Technical Service Manager
(336) 627-2502
Technical Contact
Michael Lozano
Unit Manager-Utilities &WWTP
(336) 627-2502


Comments:

Inspector's Signature:

Date of Signature:                                                                                          RS
Compliance Data
Inspection Date  02/14/2017
Inspector's Name  Maria Aloyo
Operating Status  Operating
Compliance Code   Compliance - inspection
Action Code            PCE
On-Site Inspection Result     Compliance
  Total Actual emissions in TONS/YEAR:
                                       
                                      TSP
                                      SO2
                                      NOX
                                      VOC
                                      CO
                                     PM10
                                     * HAP
2015
0.5800
 ---
0.0500
72.49
0.0500
0.4800
4899.64
2014
24.20
371.08
211.39
79.24
5.00
4.33
22953.60

                                              * Highest HAP Emitted (in pounds)
Five Year Violation History: 
Date
Letter Type
Rule Violated
Violation Resolution Date
 
04/09/2013
NOV/NRE
Permit Permit Condition
04/19/2013
03/11/2013
NOV
Permit Late Title V ACC 
03/20/2013
03/11/2013
NOV
Permit Permit Condition
03/20/2013

Performed Stack Tests since last FCE: None
Date
Test Results
Test Method(s)
Source(s) Tested
  

INTRODUCTION
ON FEBRUARY 14, 2017, Maria Aloyo, DAQ-WSRO Environmental Engineer, made contact with Mr. Michael Lozano, Utilities & WWTP Unit Manager, and Mr. Drew Lucas, Consultant, at the above referenced facility for an unannounced compliance inspection.  The facility is a beer brewing and packaging facility.  Blair Palmer, of DAQ-WSRO previously inspected this facility on September 22, 2016 and was found to be in compliance with all applicable Air Quality regulations.  During Mr. Palmer's inspection, he noted that the "facility is essentially closed and the facility will request a permit rescission soon."  Based on the two most recent quarterly reports received at DAQ-WSRO on October 20, 2016 and January 23, 2017, the facility has not been in operation since September 2016.  Since the facility is not operating and has not submitted a permit rescission request, this compliance inspection served as a status update.

PERMITTED SOURCES
EMISSION
Source ID
                          Emission Source
Description
                               Control
System ID
                          Control System
Description
                                     ES-15
                     One brewhouse cleaning vacuum system
                                   CD-15A.2
                                   CD-15B.2
One cyclone (30 inches in diameter) (CD-15A.2) and one bagfilter (86 square feet of filter area) (CD-15B.2) in series
                                       
                                       
                                   CD-15A.1
                                   CD-15B.1
One cyclone (30 inches in diameter) (CD-15A.1) and one bagfilter (86 square feet of filter area) (CD-15B.1) in series
                                     ES-24
                                 Cold services
                                      N/A
                                      N/A
                                     ES-31
                               Product packaging
                                      N/A
                                      N/A
                                     ES-32
       One quality control coding ink application on the packaging lines
                                      N/A
                                      N/A
                  ES-37 (EmGen) (NSPS IIII & NESHAP ZZZZ)
                        One (150 kW electrical output; 
                           270 hp engine) emergency 
                          diesel fuel fired generator
                                      N/A
                                      N/A
                                    ES-39 
                         (NSPS IIII & NESHAP ZZZZ)
                         One (140 HP) Diesel Fire Pump
                                      N/A
                                      N/A
                                     ES40
                   Cold cleaner degreasers (six degreasers)
                                      N/A
                                      N/A
                                      ES9
                        Hot melt adhesives application
                                      N/A
                                      N/A
                                     ES30
                           Application of label glue
                                      N/A
                                      N/A
                                    ES-41 
                         (NSPS IIII & NESHAP ZZZZ)
                         One (140 Hp) Diesel Fire Pump
                                      N/A
                                      N/A
INSIGNIFICANT/EXEMPT SOURCES
SOURCE
                             Exemption Regulation
                                Source of TAPs?
                         Source of Title V Pollutants?
                        IES1 - Warehousing operations 
                        (including bottle warehousing)
                             2Q .0102 (c)(2)(E)(i)
                                      No
                                      Yes
                            IES2 - Spent grain silo
                                       
                                      No
                                      Yes
                      IES5 - Ammonia refrigerator system
                                       
                                      Yes
                                      Yes
                          IES6 - CO2 recovery system
                                       
                                      No
                                      No
                   IES7 - Specialty malt handling/receiving
                                       
                                      No
                                      Yes
                   IES8 - Spice addition system to brewhouse
                                       
                                      No
                                      Yes
                      IES12.1, IES12.2 - Two diesel fuel 
                  storage tanks (2,500-gallon capacity each)
                             2Q .0102 (c)(1)(D)(i)
                                      Yes
                                      Yes
                          IES13 (NESHAP CCCCCC)  -  
                          One gasoline storage tank 
                            (2,500-gallon capacity)
                            2Q .0102 (c)(1)(D)(ii)
                                      Yes
                                      Yes
                            IES14 - Cooling towers
                             2Q .0102 (c)(2)(E)(i)
                                      Yes
                                      Yes
                 IES15 - Utilities carbon regeneration system
                                       
                                      No
                                      No
                          IES16 - One used oil tank 
                            (1,000-gallon capacity)
                             2Q .0102 (c)(1)(D)(i)
                                      Yes
                                      Yes
IES18 - One raw materials unloading and transfer system, including the unloading pit, and malt, grit, black malt, and 
                caramel malt silos with associated bagfilters 
                   (Nos. CD-11A and CD-11B) (formerly ES11)
                             2Q .0102 (c)(2)(E)(i)
                                      No
                                      Yes
IES19 - One grain transfer system, including Nos. 1 and 2 malt receivers, grit receiver, and malt mills with associated bagfilters 
               (Nos. CD-12A, CD-12B, and CD-12D) (formerly ES12)
                                       
                                       
                                       
IES20 - One wastewater treatment plant lime storage silo with associated bagfilter 
                          (No. CD-21) (formerly ES21)
                                       
                                       
                                       
       IES21 - General maintenance - welding, degreasing, grinding, etc.
                            2Q .0102 (c)(1)(L)(xii)
                                      Yes
                                      Yes
IES22 - Premix room, DE warehouse, Precoat and Body feed and outside the ceramic filter room controlled by multiple fabric filters 
                    for diatomaceous earth handling system
                             2Q .0102 (c)(2)(E)(i)
                                      No
                                      Yes
                   IES23 - Brewhouse (including wort tanks)
                                       
                                       
                                       
                    IES26 - Diatomaceous earth premix tanks
                                       
                                       
                                       
                   IES27 - One Igniter Oil Storage Tank for 
                      ES1 and ES2 (8000-gallon capacity)
                             2Q .0102 (c)(1)(D)(i)
                                      Yes
                                      Yes
IES28.1 - One Diesel Fuel Storage Tank for Fire Pump IES 3.1 (550-gallon capacity)
                                       
                                       
                                       
IES28.2 - One Diesel Fuel Storage Tank for Fire Pump IES 3.2 (550-gallon capacity)
                                       
                                       
                                       
IES29 - One No. 2 Oil Storage Tank for WWTP Boiler ES6 (10,000-gallon capacity)
                                       
                                       
                                       
                      IES-36 - Wastewater treatment plant
                              2Q .0102 (c)(1)(F)
                                      No
                                      No
                      IES33 - Diatomaceous earth handling
                             2Q .0102 (c)(2)(E)(i)
                                      No
                                      Yes
SAFETY/SECURITY
WHEN IN OPERATION, Safety shoes, safety glasses, hard hat and hearing protection are required at the facility.  General safety practices should always be followed.  Security guards allow state inspectors to park in the parking lot inside the facility rather than the visitors' parking lot.

LATITUDE/LONGITUDE VERIFICATION
THE LATITUDE AND LONGITUDE COORDINATES OF THE FACILITY WERE VERIFIED AND ARE CORRECTLY DOCUMENTED IN IBEAM.
APPLICABLE REGULATIONS 
MILLERCOORS, LLC is subject to the following regulations:  Title 15A North Carolina Administrative Code (NCAC), Subchapter 2D .0202, 2D .0515, 2D .0516, 2D .0521, 2D .0524 (40 CFR 60, Subpart IIII), 2D .0535, 2D .0540, 2D .0605, 2D .1100, 2D .1111 (40 CFR 63, Subpart ZZZZ), 2D .1806, 2D .2100, 2Q .0102, and 2Q .0315.
DISCUSSION
UPON ARRIVAL TO THE FACILITY, IT WAS EVIDENT THAT MILLERCOORS, LLC in Eden, NC was shut down.  This inspector met with Mr. Lozano and Mr. Lucas who confirmed that the brewing operations ceased since July 2016 and the last shipment of beer from the facility was in September 2016.  Mr. Lozano stated that the cold cleaner degreasers (ES40), hot melt adhesive application (ES9), application of label glue (ES30), and the spice addition system to brewhouse (IES8) are no longer onsite.  The only sources currently operating are the one emergency diesel-fired generator (ES-37) and the two diesel-fired emergency fire pumps (ES-39 & ES-41).  The two 550-gallons diesel fuel tanks for the fire pumps (IES28.1 & IES28.2) and the one 2,500-gallons gasoline storage tank (IES13) still contain fuel.  All other sources onsite have been cleaned /flushed and are not in operation.  Mr. Lozano and Mr. Lucas are aware of the permit recession procedure but are unsure of exactly when corporate will submit a permit rescission request to DAQ.  This inspector explained to Mr. Lozano and Mr. Lucas that although the facility is shutdown, the facility is still responsible for the reporting, recordkeeping, maintenance, and work practice requirements outlined in the permit.  After reviewing records, Mr. Lozano guided this inspector to the emergency equipment.  

PERMIT CONDITIONS
CONDITION A.2 contains the 2D .0202 permit renewal and emissions inventory requirements. The facility is required to prepare and submit a permit application and emissions inventory 90 days prior to the expiration date of the permit. The facility's permit expires on September 30, 2023 and an emissions inventory will be due for CY2022.  However, the facility plans to rescind their permit due to cessation of operations but Mr. Lozano and Mr. Lucas were unaware of the exactly when the permit rescission request will be submitted.  The facility appears to be in compliance with 2D .0202.

Condition A.3 contains the 2D .0515 requirements for controlling particulate matter emissions from miscellaneous industrial processes.  The Brew House Cleaning Vacuum System (ES-15), the Raw Materials Unloading and Transfer System (IES18), the Grain Transfer System (IES19) and the Wastewater Treatment Plant Lime Storage Silo (IES20) are subject to this rule.  According to permit review R24, the allowable emission rates for ES-15, IES18, IES19, and IES20 are 1.03 lbs./hr., 21.7 lbs./hr., 21.7 lbs./hr., and 20.3 lbs./hr., respectively.  Based on permit review R24, the facility has demonstrated compliance with this regulation.

Condition A.4 contains the 2D .0516 requirements for controlling sulfur dioxide (SO2) emissions from combustion sources.  According to this regulation, all combustion sources that discharge SO2 emissions from any stack, vent, or chimney must not emit more than 2.3 pounds of SO2 per million BTU input.  This regulation applies to the one emergency diesel-fired generator (ES-37) and the two diesel-fired emergency fire pumps (ES-39 & ES-41).  Based on permit review R24, this facility has demonstrated compliance with this regulation.

Condition A.5 contains the 2D .0521 requirements for controlling visible emissions from emission sources. According to this permit condition, visible emissions are not to exceed 20 percent opacity when averaged over a six-minute period.  Visible emission standards outlined in 15A NCAC 2D .0524 (NSPS) and 15A NCAC 2D .1111 (NESHAP) shall take precedence over the ones listed under this rule.  During the inspection, none of the emission sources were in operation.  The facility appears to be in compliance with 2D .0521. 

Condition A.6 contains the 2D .0524 the requirements for complying with the New Source Performance Standards (NSPS) federal regulations promulgated by the EPA.  The one emergency diesel-fired generator (ES-37) and the two diesel-fired emergency fire pumps (ES-39 & ES-41) are subject to 40 CFR Part 60, Subpart IIII "Standards of Performance for Stationary Compression Ignition Internal Combustion Engines" and are required to use diesel fuel with a maximum sulfur content of 15 ppm, and a minimum cetane index of 40 or a maximum aromatic content of 35% volume.  These engines are also required to have a non-resettable hour meter installed prior to start-up.  The facility is required to purchase an engine certified to the emission standards as specified under 40 CFR 60, Subpart IIII.  These units are allowed 100 hours per year for maintenance and testing.  The engines can be used for non-emergency purposes up to 50 hours per year which are counted towards the previously allotted 100 hours per year for maintenance and testing.

During the inspection, none of the engines were running.  Each engine was equipped with a non-resettable hour meter and are all certified to EPA standards.  Records show that the engines were only operated for the purpose of maintenance or testing.   Each engine runs for about 15 minutes per week as recommended by the manufacturer for testing purposes.  Mr. Lozano checks the non-resettable hour meter on each engine once per day and he provided this inspector with the logs.  In 2016, ES-37, ES-39, and ES-41 operated for 8.5, 59.1, and 41.1 hours, respectively.  Based on the non-resettable hour meters observed during the inspection, ES-37, ES-39, and ES-41 operated for 0.4, 9.4, and 6.4 hours, respectively, so far in 2017.   The most recent maintenance check performed on the three engines was on February 7, 2017.  This facility is not part of the any emergency demand response program according to Mr. Lozano.  The facility appears to be in compliance with 2D .0524 and 40 CFR 60, Subpart IIII.

Condition A.7 contains the 2D .0535 rule requiring the facility to notify the director of any excess emissions lasting longer than four hours resulting from a malfunction, a breakdown of process or control equipment.  Mr. Lozano and Mr. Lucas indicated that there had not been any excess emissions lasting more than four hours since the last inspection, especially since the facility has not been in operation since September 2016. The facility appears to be in compliance with 2D .0535.

Condition A.8 contains the 2D .0540 fugitive dust control requirements.  At the time of inspection, fugitive dust was not observed beyond the property boundary.  The property has a mixture of paved and green surfaces; therefore, fugitive dust is unlikely.  A review of the facility's file shows no recent fugitive dust complaints have been received by this office.  The facility appears to be in compliance with 2D .0540.

Condition A.9 contains the 2D .0958 work practices for sources of VOC emissions.  This regulation establishes work practices for facilities in nonattainment areas for 8-hour ozone that uses, mixes, manufactures, or emits VOCs.  On November 1, 2016, this regulation was amended and only applies to sources located in any of the designated nonattainment areas for 8-hour ozone listed under 15A NCAC 02D .0902.  Since this facility is located in Rockingham County and this county is classified as in attainment/unclassifiable for all regulated pollutants, this regulation no longer applies. However, since this facility is not operating and most of the equipment has been cleaned, it is likely that the facility is in compliance with this regulation. 

Condition A.10 contains the 2D. 1111 requirements for complying with the National Emission Standards for Hazardous Air Pollutants (NESHAP) federal regulations promulgated by the EPA.  The one emergency diesel-fired generator (ES-37) and the two diesel-fired emergency fire pumps (ES-39 & ES-41) are subject to 40 CFR Part 63, Subpart ZZZZ "National Emissions Standards for Stationary Reciprocating Internal Combustion Engines."  Since engines are classified as new stationary RICE located at an area source of HAP emissions, the facility meets the requirements of Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart IIII as discussed in Condition A.6.  The facility appears to be in compliance with 2D .1111.

Condition A.11 contains the 2D .1806 control and prohibition of odorous emissions requirements.  At the time of inspection, no objectionable odors were detected outside of the facility.  A review of the facility's file shows no recent odor complaints have been received by this office.  The facility appears to be in compliance with 2D .1806.

Condition A.12 contains the 2D .2100 Risk Management Plan requirements under 40 CFR Part 68.  This facility is specifically subject to the Program Level 3 section of 112(r) of the Clean Air Act due to the 100,000 pounds of anhydrous ammonia stored onsite.  On August 15, 2012, a full 112(r) compliance inspection was performed by Mr. Ray Stewart of DAQ-WSRO and the facility was deemed in compliance.  Since the facility ceased production, Mr. Lucas stated that the anhydrous ammonia has been removed from the facility and that the facility had deregistered from the 112(r) program.  The current 112(r) inspector from the DAQ-WSRO, Mr. Robert Barker, confirmed that the facility deregistered effective on August 30, 2016.  This condition no longer applies.

Condition A.13 requires the facility to comply with any federal rule that is applicable to sources exempted from air permitting requirements.  The exempt 2,500-gallons gasoline storage tank (IES13) is subject to 40 CFR Part 63, Subpart CCCCCC "National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities."  The gasoline storage tank is used for providing fuel to vehicles used onsite.  Currently the tank's throughput is less than 10,000 gallons per month.  Therefore, the tank is only subject to the work practice and recordkeeping requirements.  The facility must not allow gasoline to be handled in a way that would result in vapor releases.  This includes minimizing spills, cleaning up spills quickly, covering all opening to the tanks when not in use, etc.  Mr. Lozano confirmed that the facility continues to tracks the gasoline usage and to implement the work practices.  The facility appears to be in compliance with this regulation. 

Condition A.14 contains the 2Q. 0315 (Synthetic Minor) requirements in order to avoid the requirements of 2Q. 0501 (Title V).  To maintain the synthetic minor classification, the facility is limited 100 tons per consecutive 12-month period of PM10 and VOC emissions.  To ensure compliance with this requirement, the facility must perform an annual inspection of the bagfilters and cyclones.  Thirty (30) days after each calendar quarter, the facility must submit to DAQ the tons of VOC emitted for each of the three 12 month periods over the previous 14 months.

The most recent internal inspections for the cyclones and bagfilters were performed on March 9, 2016.  The VOC emissions for 2016 were estimated to be 26.04 tons per year.  The facility adequately maintains the required monthly and annual records.  The most recent quarterly report was received by DAQ on January 23, 2017.  The facility appears to be in compliance with 2Q. 0315.

NSPS/NESHAP/112(r) APPLICABILITY
THE FACILITY IS SUBJECT TO the following National Emissions Standard for Hazardous Air Pollutants (NESHAP) regulations. 

    40 CFR Part 63, Subpart ZZZZ, "National Emissions Standards for Stationary Reciprocating Internal Combustion Engines" as discussed under Condition A.10 above.
   
    40 CFR Part 63, Subpart CCCCCC, "National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Dispensing Facilities" as discussed under Condition A.13 above.

 The facility is subject to the following New Source Performance Standard (NSPS) regulations.
 
    40 CFR Part 60, Subpart IIII, "Standards of Performance for Stationary Compression Ignition Internal Combustion Engines" as discussed under Condition A.6 above.

The facility was subject to 40 CFR Part 68, "Chemical Accident Prevention Provisions" as discussed under Condition A.12 above.







FACILITY EMISSIONS
THE FACILITY-WIDE ACTUAL Emissions are listed in the table below for CY2014 and CY2015.  

                                   Pollutant
                           CY 2014 Actual Emissions
                                  [tons/yr.]
                           CY 2015 Actual Emissions
                                  [tons/yr.]
                                      PM
                                     24.2
                                     0.58
                                     PM10
                                     4.33
                                     0.48
                                     PM2.5
                                     2.17
                                     0.36
                                      SO2
                                    371.08
                                 Not Reported
                                      NOx
                                    211.39
                                     0.05
                                      CO
                                      5.0
                                     0.05
                                      VOC
                                     79.24
                                     72.49
                                   HAPTotal
                                    14.950
                                     2.54
                                  HAPHighest
                          11.477 (Hydrogen Chloride)
                                2.45 (Methanol)
PERMIT CONSIDERATIONS
THE facility plans to rescind the permit due to cessation of operations.
COMPLIANCE HISTORY
ON April 9, 2013, a Notice of Violation and Recommendation for Enforcement (NOV/NRE) was issued to the facility for failing to conduct the internal inspection of bagfilter CD-15B.2 within 12 months of the previous internal inspection.  Since the facility notified DAQ of this violation, DAQ did not pursue enforcement actions against the facility as noted in the enforcement memo issued May 10, 2013.  

On March 11, 2013, the facility received a Notice of Violation (NOV) for submitting a semiannual report and annual compliance certification with inaccurate information.  The reports did not reflect that a deviation occurred during the first half of 2012.

On August 2, 2012, a Notice of Deficiency (NOD) was issued to the facility for a late submittal of the semiannual report.  The report was due by July 30, 2012 but was received by DAQ-WSRO on August 1, 2012.
CONCLUSION
BASED ON A REVIEW OF RECORDS AND VISUAL OBSERVATIONS, the MillerCoors, LLC appeared to be operating in compliance with Air Quality rules and regulations at the time of this inspection.  
