The URL can be used to link to this page

Home My WebLink AboutAQ_F_1300101_20190327_CMPL_InspRpt NORTH CAROLINA DIVISION OF Mooresville Regional Office AIR QUALITY Blythe Brothers Asphalt Co.,LLC-Concord Plant NC Facility ID 1300101 Inspection Report County/FIPS: Cabarrus/025 Date: 03/27/2019 Facility Data Permit Data Blythe Brothers Asphalt Co.,LLC-Concord Plant Permit 07449/RI 1 660 Goodman Road Issued 2/20/2018 Concord,NC 28027 Expires 1/31/2026 Lat: 35d 24.3970m Long: 80d 42.001Om Class/Status Synthetic Minor SIC: 2951 /Paving Mixtures And Blocks Permit Status Active NAICS: 324121 /Asphalt Paving Mixture and Block Manufacturing Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Tye Pickett Frank Blythe Alec Blythe NSPS: Subpart I Plant Foreman Member Manager Air Quality Manager (704)784-5589 (704)588-0023 (704)588-0023 Compliance Data Comments: Inspection Date 03/27/2019 ✓ Inspector's Name Donna Cook Inspector's Signature: a Cook Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: L On-Site Inspection Result Compliance [2016 Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 x HAP 5.84 0.0200 4.48 8.23 22.69 4.12 1090.00 14.72 0.0100 3.08 5.64 15.56 6.70 224.93 x Highest HAP Emitted inpounds) Five Year Violation History:None Date Letter Type Rule Violated Violation Resolution Date Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested Blythe Brothers Asphalt Co., LLC—Concord Plant March 27,2019 Page 2 Type Action: X Full Compliance J Partial Compliance _Complaint Other: Evaluation Evaluation/Reinspection Investigation Data Tracking: X Date submitted for initial review 04/03/2019 V _IBEAM WARNING/OB,NOD,NOV,NRE X IBEAM Document X IBEAM Inspection list date inspected / X IBEAM LAT/LONG Facility Locked✓/ / X IBEAM Inspection, list date draft is submitted X IBEAM LAT/LONG,Coordinates checked✓ X IBEAM Inspection,pollutants/programs checked/ _IBEAM Complaint X IBEAM Planning,Next Inspection Date 03/01/2020 Directions: From Mooresville Regional Office to Concord,travel Highway 3 South;turn right on Odell School Road;turn right on Poplar Tent Road and make a U-turn at the next stop light; and 0.7 mile turn left on Goodman Road(road prior to Interstate 85); and 0.2 mile on the left is entrance to the asphalt plant. The street address of the asphalt plant is 660 Goodman Road. The Safety Equipment: This company has no safety requirements at this facility. It is recommended that steel toe shoes, hard hat and hearing protection be worn by the inspector at the asphalt plant Safety Issues: Inspector should be cautious of heavy equipment and truck traffic at the asphalt plant. Lat/Long Coordinates: The facility's coordinates on "Maps of DAQ Regulated Facilities" are not accessible on the DAQ web site. The latitude and longitude coordinates of this facility are accurate and locked in IBEAM. Email Contacts: The emails for the facility, authorized,technical, and invoice contacts were verified by Mr. Tye Pickett, plant foreman. No changes to the email addresses in IBEAM are needed. 1. The purpose of this site visit was to conduct a routine air quality inspection. Blythe Brothers Asphalt Co., LLC operates a continuous drum mix type asphalt plant that produced 333,095 tons of asphalt while burning 83,984 decatherms of natural gas during calendar year 2018. The asphalt plant operates on a varied schedule,which is dependent upon weather conditions and road projects. This facility is subject to NSPS Subpart I-"Standards of Performance for Hot Mix Asphalt Facilities". Mr. Tye Pickett, plant foreman, accompanied me during this inspection. Mr. Pickett stated that this plant operates 7 a.m.to 5 p.m., 9 hours per day, 6 days per week, 47 weeks per year. 2. Facility Contact Information: During the inspection, I verified the facility contact information in IBEAM with Mr. Pickett. No changes are needed in IBEAM. 3. Compliance history file review: No problems have been noted in the last five years by DAQ prior to this inspection. The current compliance status is discussed in the following sections. Blythe Brothers Asphalt Co., LLC—Concord Plant March 27, 2019 Page 3 4. Observations of permitted air emission sources and control devices: Emission Emission Source Control Control System Source ID Description �System ID Description 1ES-1 (NSPS) ;drum mix type, natural CD-1, CD-2 cyclone(ID No. CD-1; 8 feet ' 3gas/No. 2 fuel oiUrecycled in diameter) installed in No. 2 fuel oil/recycled No. 4 series with bagfilter(ID No. j I !fuel oil-fired hot mix asphalt CD-2; 12,818 square feet of 'plant(350 tons per hour filter area) :maximum rated capacity; f 116 million Btu per hour ;maximum heat input rate) ;Natural gas is the primary fuel source for the rotary drum aggregate dryer. No. 4 recycled fuel oil is :the secondary fuel source for the rotary drum,aggregate dryer. No. 2 fuel oil and recycled No. 2 -fuel oil are listed on the permit description as the backup fuel sources for the rotary drum aggregate dryer. r i ;This company reported that 83,984 decatherms of natural gas was combusted by the rotary drum j (aggregate dryer(ID No. ES-1)during calendar year 2018. The recycled No. 4 fuel oil,No. 2 fuel oil and recycled No. 2 fuel oil were not combusted in the rotary drum aggregate dryer during !calendar year 2018. I E The sand and aggregate materials are placed in the six bins by a front end loader. These materials fare conveyed by the six virgin aggregate feeder belts.(belt under each of the six feeders in bottom of each bin)to one aggregate collector belt conveyor and then to one vibrating double deck screen ;(two screens installed Tx 12', each). After the screening process,these materials are conveyed to one aggregate scale belt conveyor into the inlet of the rotary drum. The eight belt conveyors and ` :one vibrating double deck screen were in operation with no visible emissions observed. The reclaimed asphalt pavement(rap) is placed by front end loader into two grizzly screens and '-then dropped into two feeder bins. From the bottom of the feeder bin, the rap is conveyed to two ;feeder belts(one belt under each feeder in the bottom of each bin)to one collector belt conveyor and then to one vibrating single deck screen(3'x 6'). Then the oversized materials from the vibrating single deck screen drops from a chute onto another belt conveyor and then conveyed to the; 1hammermill to be crushed. After the crushing process,.the rap materials are returned by the s�collector belt conveyor to the vibrating single deck screen and then conveyed to one scale belt conveyor and then into the rotary drum. The five belt conveyors and one vibrating double deck screen were in operation with no visible emissions. Mr.Pickett stated that 30%rap is being used in j ;the hot mix asphalt product. t This company hired Red Clay Industries,Inc.to crush rap at the asphalt plant. I observed that the portable diesel-fired rap crushing, screening and conveying plant owned and operated by Red Clay ;Industries, Inc. was on-site,but no crushing of rap was being conducted. Mr. Pickett stated that this 'company crushed 66,464.42 tons of rap in calendar year 2018. 'On November 18, 2015,this office received an application for pen-nit modification to replace the existing bagfilter(9,672 square feet of filter area)with a new bagfilter(12,818 square feet of filter urea). Mr. Pickett stated that the bagfilter(12,818 square feet of filter area; manufacturer,Herman ;Grant Co.)was installed from December 22, 2015 to January 31, 2016 and became operational on Blythe Brothers Asphalt Co.,LLC—Concord Plant March 27, 2019 Page,4 ............................................:......._._.._............................................._...._................::....................................................................................................................................................................................................... January 31, 2016. The cyclone(ID No. CD-1; 8 feet in diameter)was not replaced by this ,company. The particulate matter emissions from the rotary drum aggregate dryer are exhausted into the cyclone and then to the pulse jet type bagfilter(12,818 square,feet of filter area; manufacturer, Herman Grant Co). At the base of the cyclone and bagfilter,the particulate matter emissions are screw conveyed to the incline auger and then into the rotary drum. This company has a gauge (Goyer demand cleaning)measured in inches of water that is used to determine the pressure differential across the bagfilter. The gauge is located at ground level near the bagfilter. Observed. The continuous drum mix asphalt plant was operating at 160 tons per hour and =producing surface and base mix asphalt products during the inspection. The mix temperature in the rotary drum aggregate dryer was recorded at 300 degrees Fahrenheit. The rotary drum aggregate (dryer was firing on natural gas. The pulse jet type bagfilter was in operation. The pressure !differential gauge across the bagfilter read .4 inches of water.. I observed no visible emissions !except for the dissipation of the steam plume from the exhaust of the vertical and uncapped bagfilter - [stack. _ ES-2, ES-3, ES-4 ithree(3)HMA storage silos N%A N/A (200 tons capacity, each) The hot mix asphalt product from the rotary drum aggregate dryer is conveyed by the drag slat to .the two hot mix asphalt(hma) conveyors(referred to as the traverse conveyors by this company). !The two hma conveyors are located above the three hot mix storage silos (ID Nos.ES-2,ES-3,ES-4 jor company ID Nos. 1, 2 and 3). The hot mix asphalt product is transported by the two hma ;conveyors into a designated hot mix storage silo by the plant operator. The hot mix asphalt is stored in the three hma storage silos. The three silos(ID Nos. ES-2 or 41; ES-3 or#2 and ID No. ES-4 or#3)are electrically heated. The hot mix asphalt is gravity dropped ;from the three hma storage silos into the beds of dump trucks: i :Observed. One silo(ID No. ES-2 or#1) contained surface mix asphalt product. A second silo (ID No. ES-3 or#2; new silo installed January 2017,which was like-for-like)contained base mix asphalt product. The third silo (ID No. ES-4 or#3)contained surface mix asphalt product. The hot ;mix asphalt products were being gravity dropped from the three storage silos into the beds of dump trucks. I observed no visible emissions from the three hma storage silos or the gravity dropping of iasphalt products from the three hma storage silos into the bed's of dump trucks. _.._............_.........................................................................................................................................................................................................................................................................................................................................................................................................._.................... 5. Observations of insignificant air emission sources and control'devices listed on the current permit: Exemption Source of Source of Title V Source Reg ulation TAPs? Pollutants? TIES-2 -natural gas/No. 2 fuel oil-fired hot oil 2Q 0102 :heater(2.2 million Btu per hour maximum heat: (h)(1)(A) Yes Yes `input rate) _ :The Heatec model natural gas-fired hot oil heater is used heat the hot oil in two compartment liquid :asphalt tank(ID No. IES-3); one heat exchanger(pre-heater for No. 4 recycled fuel oil); asphalt :drag slat conveyor; hot oil lines for mixer(bottom outer shell!drum or mixing chamber)and one :traverse conveyor. The hot oil.is recirculated. The hot oil heater is located underneath a shed. ....................................................................................................-.........._................................................................................................................._........................................................................................................................................................................................._...__.............................. Blythe Brothers Asphalt Co.,LLC—Concord Plant March 27, 2019 Page 5 _...... .............. .....:.............:......:....::.._...:....:.:.........:.................:...................... ._.......:....... ...... :.........:...._............ ..... .._._....... ............... ..._.............................._...............................................:.......................... ............. ........... ...... .............:................. ....._...................... ....................... ........................ No. 2 fuel oil is listed as the backup fuel source for the hot oil heater. The heater has the capability to operate on No. 2 fuel oil if it was connected to the No. 2 fuel oil line. Mr. Pickett stated that hot :oil heater has never been installed on the No. 2 fuel oil line and never operated on No. 2 fuel oil. :Observed. The hot oil heater was operating on natural gas. I observed no visible emissions from :the vertical exhaust with rain cap of the hot oil heater. :IES-3 -two compartment liquid asphalt p q p 12Q .0102 storage tank(capacities of 20,000 and 10,000 No No ;gallons per compartment) (g)(14)(B) :The liquid asphalt is stored in the two compartment liquid asphalt storage tank(20,000 and 10,000 ;gallons, each; installed 1992). The liquid asphalt is mixed with sand, aggregate and rap in the rotary :drum and then heated by the dryer to produce the hot mix asphalt product. 'Observed. The liquid asphalt was being mixed in the rotary drum with sand, aggregate and rap and then heated by the dryer to produce the hot mix asphalt product. I observed no visible emissions from the two compartment liquid asphalt storage tank(20,000 and 10,000 gallons). IES-4 -recycled No. 4 fuel oil storage tank (20,000 gallon capacity) 32Q .0102 (g)(4) Yes Yes 'Mr. Pickett stated that this tank is referred to as the holding tank. No. 4 recycled fuel oil is used as :the secondary fuel source for the rotary drum aggregate dryer. A heat exchanger(pre-heater) is :used to heat the No. 4 recycled fuel oil prior to the rotary drum aggregate dryer. :Observed. The No. 4 fuel oil tank was not in use during the inspection. IES-5 -recycled No. 4 fuel storage tank2Q .0102 (g)(4) Yes _ Yes (12,000 gallon capacity) Mr. Pickett stated that this tank is referred to as the burn tank. The No. 4 recycled fuel oil is used as the secondary fuel source for the rotary drum aggregate dryer. A heat exchanger(pre-heater) is :used to heat the No. 4 recycled fuel oil prior to the rotary drum aggregate dryer. :Observed. The No. 4 fuel oil tank was not in use during the inspection. :IES-6 -No. 2 fuel oil storage tank(20,000 '2Q .0102 (g)(4) Yes Yes gallon capacity) The No. 2 fuel oil (off-road virgin) is used in the front end loader and truck. The No. 2 fuel oil :could be used as the backup fuel source for the rotary drum aggregate dryer(ID No. ES-1) and the hot oil heater(ID No. IES-2). The rotary drum aggregate dryer is currently operating on natural ;gas. The hot oil heater has never been installed on the No. 2 fuel oil line and never operated on No. 2 fuel oil. :Observed. The No. 2 fuel oil was not in use during the inspection. 6. Observations of air emission sources and control devices not listed on the current permit: a. This company has a heat exchanger(referred to by this company as the pre-heater)that is used to heat the No. 4 recycled fuel oil using thermal fluid(hot oil flows through coils and transfers heat to the No.4 recycled fuel oil)from the two No. 4 recycled fuel oil tanks (ID Nos. IES-4, 20,000 gallon capacity; and IES-5, 12,000 gallon capacity)prior to the burner of the rotary drum aggregate dryer. Blythe Brothers Asphalt Co.,LLC—Concord Plant March 27, 2019 Page 6 b. A release agent (manufacturer, ChemStation, Co. of NC; and product name 4147) is sprayed in the beds of trucks prior to the asphalt loadout process. The release agent stops the bonding of the asphalt to the beds of the trucks: C. This company has two hma conveyors(referred to as traverse conveyors)to transport the hot mix asphalt product into designated hot mix storage silos(ID Nos. ES-2 or#1; ES-3 or#2; and ES-4 or#3)by the plant operator. d. This company has eight aggregate belt conveyors; one vibrating aggregate double deck screen(5'x 12% 400 tons per hour maximum process rate; five rap conveyors; one rap hammermill (12 tph maximum rated capacity); and one single rap deck screen(3'x 6; 180 tons per hour maximum rated capacity). These,sources were permitted under revision 9 and removed from revision 10. These sources are not listed on the permit because they are considered fugitive sources. The conveyors and screens were in operation during the inspection. I observed no visible emissions from the conveyors and screens during the inspection. e. This company has two aboveground diesel tanks (2000 gallons, each)that are used to fuel the shop trucks for Blythe Development. Mr. Pickett stated that one tank has on- road diesel fuel and the second tank has off-road diesel fuel. The two diesel fuel tanks are exempt per 15A NCAC 2Q .0102 (g)(4). 7. Compliance with specific permit conditions and limitations: a. Condition A. 2. Permit Renewal and Emission Inventory Requirement—The permittee at least 90 days prior to the expiration date of this permit, shall request permit renewal by letter with an application form and submit the air pollution emission inventory report with certification sheet for 2024 calendar year to MRO DAQ. Observed. I informed Mr.Pickett that the current air permit will expire on January 31, 2026. Compliance with this stipulation is indicated. b. Condition A. 3. Particulate Control Requirement-As required by 15A NCAC 2D .0506 "Particulates from Hot Mix Asphalt Plants," i. Particulate matter emissions resulting from the operation of a hot mix asphalt plant shall not exceed allowable emission rates. ii. Visible emissions from stacks or vents at a hot mix asphalt plant shall be less than 20 percent opacity when averaged over a six-minute period. iii. _ Fugitive non-process dust emissions shall be controlled as required by 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emission Sources." iv. Fugitive emissions for sources at a hot mix asphalt plant not covered elsewhere under this Rule shall not exceed 20 percent opacity averaged over six minutes. Observed. During the inspection,I observed no visible emissions except for the dissipation of a steam plume from the exhaust of the bagfilter stack or fugitive emissions from this facility. Compliance with this stipulatiodis indicated. Blythe Brothers Asphalt Co., LLC=Concord Plant March 27,2019 Page 7 C. Condition A. 4. Sulfur Dioxide Control Requirement- As required by 15A NCAC 2D .0516 "Sulfur Dioxide Emissions from Combustion Sources," sulfur dioxide emissions from the combustion sources shall not exceed 2.3 pounds per million Btu heat input. Observed. Per MRO memo "2D .0516 analysis" dated 04/10/97, compliance is indicated for No. 1 fuel oil,No. 2 fuel oil, natural gas, butane, propane,and wood fuel. Compliance with this stipulation was indicated during the permit application process. d. Condition A. 5. Visible Emissions Control Requirement-As required by 15A NCAC 2D .0521 "Control of Visible Emissions,"visible emissions from the emission sources, manufactured after July 1, 1971, are limited to 20 percent opacity when averaged over a six-minute period. Observed. The asphalt plant was in operation during the inspection. I observed no visible emissions except from the dissipation of steam from the exhaust of the bagfilter stack or any other sources at this facility. Compliance with this stipulation is indicated. e. Condition A. 6. 15A NCAC 2D .0524 "New Source Performance Standards" -For asphalt plant(ID No.ES-1),the permittee must comply with all applicable provisions including notification,testing,reporting,recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D .0524 "New Source Performance Standards" (NSPS) as promulgated in 40 CFR 60, Subpart I, including Subpart A, "General Provisions." i. NSPS Emissions Limitations-As required by 15A NCAC 2D .0524,the permittee shall not discharge or cause the discharge into the atmosphere from any affected source any gases which: A. Contain particulate matter in excess of 90 mg/dscm (0.04 gr/dscf); or B. Exhibit 20 percent opacity or greater. Observed. The asphalt plant was in operation during the inspection. I observed no visible emissions except for the dissipation of the steam plume from the exhaust of the bagfilter stack. Compliance with this stipulation is indicated. f. Condition A. 7.Notification Requirement-As required by 15A NCAC 2D .0535,the permittee of a source of excess emissions that last for more than four hours and that results from a malfunction,a breakdown of process or control equipment or any other abnormal conditions, shall notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time of the Division's next business day of becoming aware of the occurrence. Observed. Based on records review and the conversation with Mr. Pickett, no excess emissions have occurred at the facility. Compliance with this stipulation is indicated. g. Condition A. 8. Fugitive Dust Control Requirements-As required by 15A NCAC 2D .0540 "Particulates from Fugitive Dust Emissions Sources," the permittee shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. If substantive complaints or Blythe Brothers Asphalt Co., LLC—Concord Plant March 27,2019 Page 8 excessive fugitive dust emissions from the facility are observed beyond the property boundaries for six minutes in any one hour(using Reference Method 22 in 40 CFR, Appendix A),the owner or operator may be required to submit a fugitive dust plan as described in 2D .0540(f). Observed. MRO DAQ has not received any fugitive dust emissions complaints regarding this facility. Mr. Pickett stated that Vulcan Construction Materials,LLC, Cabarrus Quarry has a water truck that wets the unpaved areas at this asphalt plant for this company. The plant roads at this facility were wet due to recent rainy weather. I observed no fugitive emissions from the unpaved areas at this facility. Compliance with this stipulation is indicated. h. Condition A. 9.Testing Requirement-Under the provisions of North Carolina General Statute 143-215.108 and in accordance with 15A NCAC 2D .0605,the permittee shall demonstrate compliance with the emission limit(s)by testing the emission source(s) for the specified pollutant(s)as follows: _. _... ._.... ---... --....._..__._(....).......................... --...._................ ...................... --- ..............._.....__....._.........._......... _..... .................._........_........................... Affected Sources Po Ilutant TargetTest Method Parameter drum mix type, natural gas/No. 2 fuel oil/ recycled No. 2 fuel oil/recycled No.4 fuel oil- fired hot mix asphalt plant(350 tons per hour PM(TSP) 60 lb/hr Method 5 maximum rated capacity; 116 million Btu per hour maximum heat input rate) (ES-1) drum mix type, natural gas/No. 2 fuel oil/ — recycled No. 2 fuel oil/recycled No.4 fuel oil- fired hot mix asphalt plant(350 tons per hour PM(TSP) 60 lb/hr Method 202 maximum rated capacity; 116 million Btu per hour maximum heat input rate) (ES-1) drum mix type, natural gas/No. 2 fuel oil/ DAQ recycled No. 2 fuel oil/recycled No. 4 fuel oil- Visible Appr-eved fired hot mix asphalt plant(350 tons per hour 20% opacity Methed maximum rated capacity; 116 million Btu per Emissions Change to hour maximum heat input rate)(ES-1) Method 9 Observed. This facility is required per DAQ memo to perform the particulate matter (methods 5 and 202) and visible emissions(method 9)testing on the rotary drum mix asphalt dryer once every ten years. This office sent a letter dated September 13, 2013 advising this facility of emission testing procedures. The last stack testing for visible(EPA reference method 9)and particulate(EPA reference method 1-5-filterable PM&202-condensible PM)emissions testing of the hot mix asphalt plant was performed by Analytical Testing Consultants, Inc. (ATC)on July 23, 2009. This plant was burning recycled No:4 fuel oil and the averaged production rate of asphalt was 349.9 tons per hour. The results of this testing indicated that this asphalt plant had a filterable particulate matter(PM)emission rate of 30.7 mg/dscm or 2.52 lb/hr;total particulate matter(PM) Blythe Brothers Asphalt Co.,LLC—Concord Plant March 27,2019 Page 9 emission rate of 3.121b/hr; condensable particulate matter(PM) emission rate of 0.60 lb/hr; and Method 9 visible emissions evaluation for the highest six-minute average was 0% opacity. These tests demonstrated compliance with the NSPS filterable particulate matter(PM) emission limit of 90 mg/dscm in accordance with 15A NCAC 2D .0524 NSPS as promulgated in 40 CFR Part 60.NSPS Subpart I "Standards of Performance For Hot Mix Asphalt Facilities;total particulate matter(PM)emission limit of 60.0 lb/hr in accordance with 15A NCAC 2D .0506 "Particulates From Hot Mix Asphalt Plants"; and visible emissions limitation of 20% opacity in accordance with 15A NCAC 2D .0524 NSPS; 15A NCAC 2D .0521 "Control of Visible Emissions" and 40 CFR Part 60 NSPS Subpart I "Standards of Performance For Hot Mix Asphalt Facilities." This office sent a letter dated November 19,2009 to this company stating that the results of these tests indicated compliance with the applicable particulate matter and visible emissions limitations. The next stack test must be completed and the results submitted to MRO I)AQ by July 31,2019. Mr. Pickett and I discussed the submittal of a protocol at least 45 days prior to performing the required air emission testing and the testing results deadline of July 31, 2019. Compliance with this stipulation is indicated. i. Condition A. 10. Fabric Filter Requirements including cartridge filters, baghouses, and other dry filter particulate collection devices - As required by 15A NCAC 2D .0611, particulate matter emissions shall be controlled as described in the permitted equipment list. The permittee shall perform, at a minimum, an annual internal inspection of the particulate collection device system within 12 month period following the initial inspection. In addition, the permittee shall perform periodic inspections and maintenance as recommended by the equipment manufacturer. The results of all inspections and any variance from manufacturer's recommendations shall be investigated with corrections made and dates of actions recorded in the logbook (in written or electronic format). The logbook shall be kept on-site and made available to DAQ personnel upon request. Observed. The logbook provided by Mr. Pickett indicated that the inspection and maintenance activities are being performed on the bagfilter by this company. This company conducted the internal inspections of the bagfilter on 3/26/19; 3/23/19; 3/19/19; 3/6/19; 2/12/19; 2/5/19; 2/4/19; 1/14/19; 1/7/19; 1/2/19; 6/7/18; 4/26/18; 4/3/18; 3/21/18; 3/1/18; 12/18/17; 9/13/17; 5/4/17; 4/12/17 and 1/10/17. The inspections of the bagfilter are within the 12 month period time frame as indicated by this condition. This facility is required by General Condition and Limitation B. 2. of the current permit to keep records on site for a minimum of two years. The records of the bagfilter inspection and maintenance activities are being kept by this company for more than two years. Compliance with this stipulation is indicated. j. Condition A. 11. Cyclone Requirements-As required by 15A NCAC 2D .0611, particulate matter emissions shall be controlled as described in the permitted equipment list. The permittee shall perform, at a minimum, an annual inspection of cyclone system within 12 month period following the initial inspection. In addition,the permittee shall perform periodic inspections and maintenance as recommended by the equipment manufacturer. The results of all inspections and any variance from manufacturer's recommendations shall be investigated with corrections made and dates of actions I i Blythe Brothers Asphalt Co., LLC—Concord Plant March 27, 2019 Page 10 recorded in the logbook(in written or electronic format). The logbook shall be kept on- site and made available to DAQ personnel upon request. Observed. The logbook provided by Mr. Pickett! indicated that the inspection and maintenance activities are being performed on the cyclone by this company. This company conducted the inspections of the cyclone on 3/1/19; 3/1/18; 9/13/17 and 1/10/17. The inspections of the cyclone are within the 12 month period time frame as indicated by this condition. This facility is required by General Condition and Limitation B. 2. of the current permit to keep records on site for a minimum of two years. The records of the cyclone inspection and maintenance activities are being kept by this company for more than two years. Compliance with this stipulation is indicated. k. Condition A. 12. Control and Prohibition of Odorous Emissions-As required by 15A NCAC 2D .1806 "Control and Prohibition of Odorous Emissions," the permittee shall not operate the facility without implementing management practices or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary. Observed. MRO DAQ has not received any odor complaints concerning this facility. During the inspection,the asphalt plant was in operation. I detected a noticeable asphalt odor at this facility,which is consistent with normal operations. Compliance with this stipulation is indicated. 1. Condition A. 13. Limitation to Avoid 15A NCAC 2Q�:.0501 -Pursuant to 15A NCAC 2Q .0315 "Synthetic Minor Facilities,"to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of Section and Requirement for a Permit," as requested by the permittee, facility-wide emissions shall be less than the following: _...................._.........................................................................._..._.........._................_.._............................................._............._...._...._.........._..........._..........................._.......................................................................................................................... Pollutant Emission Limit j (Tons per consecutive 12-month period) ...................................................._._....................................._.........................................................................................................._....................................__............................................................................................................................................................ SOz 100 CO j 100 i. Operations Restrictions-To ensure emissions do not exceed the limitations above,the following restrictions shall apply: A. the amount of asphalt produced shall be less than 1,494,000 tons per consecutive 12-month period when burning natural gas or No. 2 fuel oil/No. 2 recycled oil that is 0.5% sulfur by weight; B. the asphalt produced shall be less than 320,000 tons per consecutive 12- month period when combusting recycled No. 4 fuel oil that is 2.0% sulfur by weight; C. If multiple fuels are used, emissions should be determined using the sum of the individual emissions rates. Blythe Brothers Asphalt Co.,LLC—Concord Plant March 27, 2019 Page 11 ii. Recordkeeping Requirements- A. The permittee shall record monthly and total annually the following: 1. the tons of asphalt produced for each fuel type. 2. the facility-wide CO and S02 emissions. B. Fuel supplier certification shall be kept on-site and made available to DAQ personnel upon request. Observed. The records of the asphalt production are kept by this company on a daily basis. The monthly and annual asphalt production records and calculated emissions data of S02 and CO are compiled by Mr. Alec Blythe, air quality manager;and Mr. Pickett. The recycled No. 4 fuel oil was not combusted by the rotary aggregate dryer during calendar year 2018. The recycled No. 4 fuel oil was last combusted in the rotary drum aggregate dryer on January 31, 2014 due to natural gas curtailment by the supplier. This company has fuel oil certification records on site indicating that the sulfur content of the No. 4 recycled fuel oil is below the allowable limit. Compliance with this stipulation is indicated. iii. Reporting Requirements-Within 30 days after each calendar year,regardless of the actual emissions,the permittee shall submit the following: A. emissions and/or operational data listed below. The data should include monthly and 12 month totals for the previous 12 month period. 1. the tons of asphalt produced for each fuel type. 2. the facility-wide S02 and CO emissions. Observed. The annual report for calendar year 2018 was received by this office on January 24, 2019. This company reported the following information: 0.03 tons of sulfur dioxide(S02)emissions; 22.86 tons of carbon dioxide(CO) emissions; 333,095 tons of asphalt when combusting 83,984 decatherms of natural gas in the rotary aggregate dryer; and no fuel oils were combusted in the rotary aggregate dryer during calendar.year 2018. Compliance with this stipulation is indicated. in. Condition A. 14. Limitation to Avoid 15A NCAC 2D .0530 "Prevention of Significant Deterioration"—In accordance with 15A NCAC 2Q .0317,to comply with this permit and avoid the applicability of 15A NCAC 2D .0530 "Prevention of Significant Deterioration," as requested by the permittee, emissions shall be limited as follows: Affected Sources) Pollutant Emission Limit (Tons Per Consecutive 12-month Period) Facility Wide �S02 250 i. i Blythe Brothers,Asphalt Co., LLC—Concord Plant j March 27,2019 Page 12 Observed. The facility-wide S02 emissions were reported by this company as 0.03 tons during calendar year 2018. Compliance with this stipulation is indicated. n. Condition A. 15. Vendor Supplied Recycled No(s). 2 and 4 Fuel Oil Requirements - In accordance with Rule 2Q .0317, the permittee is avoiding the applicability of Rule 2Q .0700 by using recycled. fuels which are equivalent to their virgin counterparts. The permittee is allowed to use the recycled fuel oil(s) as follows: i. Specifications-The recycled fuel oil(s)have to be equivalent to unadulterated fossil fuel by meeting the following criteria: .................. ........................:......._.._................................................._.................................................................................................................... Constituent/Property Allowable Level Arsenic� m�mm�mm� 1.0 ppm maximum Cadmium 2.0 ppm maximum ............................._........._.................. ......_.._._._................. . Chromium 5.0 ppm maximum Lead 100 ppm maximum Total Halogens 1000 ppm maximum ............._.._......_...._.........._..._......................................................................................................................... ..............................._..............................................................................................................._._............_......_............................. Flash Point i No. 2 100°F minimum No. 4 ; 130T minimum _...__...._............... Sulfur No. 2 0.5% maximum(by weight) No. 4 2.0%maximum(by weight) ............................................................................_......._........_...__....................._.........................................;.................... ......................................................................................................................................_.........................._................ Ash 1.0/o maximum ii. The permittee is responsible for ensuring that the recycled fuel oil(s),-as received at the site,meet(s)the approved criteria for unadulterated fuel. The permittee is held responsible for any discrepancies discovered by DAQ as a result of any sampling and analysis of the fuel oil(s). iii. Recordkeeping Requirements-The permittee shall maintain at the facility for a minimum of three years, and shall make available to representatives of the DAQ upon request, accurate records of the following: 1 A. The actual amount of recycled fuel�oil(s)delivered to,and combusted at the facility on an annual basis. B. Each load of recycled fuel oil received shall include the following: 1. A delivery manifest document clearly showing the shipment content and amount, its place and date of loading, and place and date of destination. 2. A batch specific analytical report that contains an analysis for all constituents/properties listed above. Analytical results of the samples representative of.the recycled oil shipment from the vendor shall be no more than one year old when received. Blythe Brothers Asphalt Co.,LLC—Concord Plant March 27,2019 Page 13 3. Batch signature information consisting of the following: a batch number, tank identification with batch volume of recycled oil, date and time the batch completed treatment, and volume(s) delivered. 4. A certification indicating that the recycled fuel oil does not contain detectable PCBs(<2ppm). iv. The DAQ reserves the right to require additional testing and/or monitoring of the recycled fuel oil(s) on an annual basis or without notice. Observed. This company is keeping records of the recycled No. 4 fuel oil delivered and combusted by the rotary drum aggregate dryer at this facility. The annual report for calendar year 2018 was received by this office on January 24,2019. The recycled No. 4 fuel oil was not combusted by the rotary drum aggregate dryer during calendar year 2018. The recycled No. 4 fuel oil was last combusted in the rotary aggregate dryer on January 31, 2014 due to natural gas curtailment by the supplier. Compliance with this stipulation is indicated. 8. NSPS/NESHAP Review: The asphalt plant is subject to NSPS Subpart I - Standards of Performance for Hot Mix Asphalt Facilities. This company does not own or operate any rap crushing, screening, and conveying equipment. However, the portable rap crushing, screening, and conveying operations conducted by an outside contractor at this facility is subject to NSPS Subpart 000 — Standards of Performance for Nonmetallic Mineral Processing Plants. No crushing, screening, or conveying equipment was on- site during the inspection. Any portable diesel-fired internal combustion engines operated at this facility are not subject to NSPS Subpart I11I (41) and NESHAP Subpart ZZZZ (4Z), since these engines are classified as a "nonroad engine" according to 40 CFR 1068.30 and covered under Title II of the Clean Air Act. The asphalt plant is not subject to MACT Subpart LLLLL—Asphalt Processing and Asphalt Roofing Manufacturing. This company has no boilers, emergency/peak shaving generators, fire pump engines or gasoline storage tanks at this facility. The natural gas-fired/No. 2 fuel oil-fired hot oil heater(ID No. IES-2) is excluded from the definition of a boiler as specified in 63.11237 of National Emission Standards for Hazardous Air Pollutants(NESHAP)for Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, Subpart JJJJJJ or 6J). Therefore,this process heater is not subject to the area source boiler NESHAP Subpart 6J. 9. Summary of changes needed to the current permit: a. The test method for visible emissions should be changed from DAQ Approved Method to Method 9 in condition A. 9. Testing Requirement. Blythe Brothers Asphalt Co.,LLC—Concord Plant March 27,2019 Page 14 b. The electronic yellowsheet for permit changes needed has been completed and placed in the facility's electronic file. 10. Compliance assistance offered duringthe he inspection: i I informed Mr. Alec Blythe, air quality manager, and Mr.;Tye Pickett, plant foreman, that the submittal of a protocol is due at least 45 days prior to the 'required air emission testing and the testing results deadline is July 31, 2019. 11. Section 112(r)gpplicability: ` f This facility does not appear to be subject to the requirements of the Chemical Accident Release Prevention Program,.Section 112(r) of the Clean Air Act. i 12. Compliance determination: Based on my observations, this facility appeared to be inl compliance with the applicable air quality regulations at the time of the inspection. j DLC:lhe c: MRO File i https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/CABARRUS/00101/INSPECT_20190327.docx i I I I i i i i i I I