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HomeMy WebLinkAboutAQ_F_1600074_20170329_CMPL_InspRpt NORTH CAROLINA DIVISION OF Wilmington Regional Office AIR QUALITY Slurry Pavers,Inc. NC Facility ID 1600074 Inspection Report County/FIPS: Carteret/031 Date: 03/31/2017 Facility Data Permit Data Slurry Pavers,Inc. Permit 00056/T18 107 Arendell Street Issued 6/26/2014 Morehead City,NC 28557 Expires 5/31/2019 Lat: 34d 43.1000m Long: 76d 42.0510m Classification Title V 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/Title V David Callahan Phillip Tarsovich Phillip Tarsovich Plant Manager President President (252)222-3332 (804)264-0707 Compliance Data Comments: Facility was found in compliance during the inspection Inspection Date 03/29/2017 Inspector's Name Mark Hedrick Inspector's Signature: Mark Hedrick Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: 3/31/17 On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2015 3.41 --- 4.72 10.83 2.79 3.13 --- 2014 1.86 0.0100 3.20 5.77 1.67 1.74 --- 2013 2.33 0.0200 2.03 6.88 0.5500 2.12 --- Highest HAP Emitted(in pounds) 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 Full Compliance Inspection 3/29/17 Slurry Pavers Compliance Inspection 3/29/17 Page 2 of 19 General Facility Summary The facility can be reached by taking Hwy. 70 through Morehead City. Before taking the bridge to Beaufort, veer right into the State Ports. The plant is on the right; the office is by the parking lot. An escort is now required to drive onto the port. In addition to standard safety gear, long sleeves are required here. The facility used to have a permitted roofing operation in another building. That process shutdown around 1996. The facility has been repairing and rebuilding since being bought from the previous owners in 2010, and only began asphalt storage and distribution in January 2013. Now, they are only being used as an asphalt distribution terminal with no processing. On March 10, 2014, they switched their primary fuel from ultra-low sulfur No. 2 fuel oil to LP (propane) gas. Zero visible emissions were observed for all emission sources, and all required recordkeeping and reporting requirements are being met. Consider this facility as being in compliance with all NCDAQ regulations. Comments for each Permit Specific Condition are written in Bold Italics. See Inspection Results beginning on page 17. Currently Permitted Sources: Permit No. 00056T18 Emission Emission Source Description Control Device Control Device Description Source ID No. I ID No. Emission Unit Group 1 (ID No.EU 1) EU 1.1 One natural gas/cutter stock/Nos.2,4,5,or 6 fuel NA NA oil-fired boiler(20.9 million Btu per hour maximum heat input capacity) Emission Unit Group 2(ID No.EU 2) EU 2.1 through Four storage tank(Nos. 1 through 4) NA NA EU 2.4 EU 2.5 and EU Two storage tanks(Nos. 6 and 7) F 001 Fiber bed filter 2.6 (12 square feet of filter area) EU 2.7 through Three storage tanks(Nos. 10, 15 and 16) F 002 Fiber bed filter EU 2.9 (12 square feet of filter area) EU 2.10 Six storage tanks(Nos. 18 through 23) NA NA through EU 2.15 EU 2.17 and Two storage tanks(Nos. 33 and 34) F 003 Fiber bed filter EU 2.18 (12 square feet of filter area) Emission Unit Group 5(ID No.EU 5) EU 5.1 and Two loading racks(East and West) F 004 Fiber filter bed EU 5.2 (75 square feet of filter area) EU 5.3 Railcar Loading Rack West NA NA Insignificant Activities at this Facility Attachment to Air Permit 00056T18 List of Insignificant Activities under 15A NCAC 2Q .0503(8) Slurry Pavers Compliance Inspection 3/29/17 Page 3 of 19 Emission Source I.D. Emission Source Description I-ARD Asphalt Road dust I-EU-1.4 0.8 MMBtu/hr burner I-EU-3.1 450 gallon capacity recycle asphalt tank I-EU-3.2 1500 gallon capacity recycle asphalt tank I-EU-6.1 Storage tank#5A I-EU-6.3 Storage tank#8 I-EU-6.4 Storage tank#25 I-PS-1 Pouring System I-ST-35 Storage tank#35 I-ST-36 Fuel oil storage tank#36 (75,000 gallon storage capacity) I-US-1 Unloading system I-WRT-1 Water reclamation tank This facility was issued a renewed Air Permit T18 on 6/26/14 with the following changes: The following table lists all changes associated with this renewed permit: Page(s) Section Description of Change(s) Attachment Insignificant Activities +Remove tank burner#6 (ID No. I-EU-1.6), tank burner #16 (ID No. I-EU-1.7)and storage tank#9(ID No. I-EU- 6.2 All All +Update dates and permit revision number 3 Permitted Items +Remove No. 3 preheater(ID No. EU 1.3) +Remove No. 4 preheater(ID No. EU 1.5) +Remove three (Nos. 1, 2 and 3) converters (ID Nos. EU 4.1,4.2 and 4.3)and associated thermal oxidizer/preheater (ID No. TO 001) +Remove 15A NCAC 2Q .0501(c)(2)footnote language associated with ID Nos. EU 1.5 and EU 4.3 4-6 2.1 A +Remove No. 3 preheater(ID No. EU 1.3) and No. 4 preheater(ID No. EU 1.5)from Section 2.1 A 4-11 "Testing"paragraphs +Update testing paragraphs to refer solely to General Condition JJ and header citations to 15A NCAC 2Q .0508(f) 6-11 "15A NCAC 2D .0521" +Update 15A NCAC 2D .0521 monitoring paragraphs to paragraphs refer solely to 15A NCAC 2D .2610 instead of 15A NCAC 2D .2601 7 2.1 A.4 +Add GACT JJJJJJ avoidance condition to boiler ID No. EU 1.1 9-14 (T17) 2.1 C (T17) +Remove this entire section consisting of three(Nos. 1,2 and 3) converters (ID Nos. EU 4.1,4.2 and 4.3) and associated thermal oxidizer/preheater(ID No. TO 001). 12 2.2 A.1 +Remove"and whose emissions of VOC are greater than 15 pounds per day"to reflect the current 15A NCAC 2D .0900 rules Slurry Pavers Compliance Inspection 3/29/17 Page 4 of 19 Page(s) Section Description of Change(s) 13 2.2 A.3 +Remove No. 3 preheater(ID No. EU 1.3),No. 4 preheater (ID No. EU 1.5),thermal oxidizer/preheater(ID No. TO 001)and Nos. 1,2 and 3 converters (ID Nos. EU 4.1,4.2 and 4.3) from Section 2.2 A.3 15-end 3 +Update General Conditions to version 3.6 *Note: The Permittee was subject to the New Source Performance Standards for Asphalt Processing and Asphalt Roofing Manufacture(40 CFR 60, Subpart UU)for one converter(ID No.EU 4.3). However,the No. 3 convertor (ID No. EU 4.3) was removed as part of the 6/26/14 renewal so the facility is no longer subject to NSPS Subpart UU. As described in the Permit Application Summary,NSPS Subpart UU is only applicable to saturators or mineral handling and storage facilities constructed/modified after November 18, 1980 and asphalt storage tanks or blowing stills constructed/modified after May 26, 1981. The boiler (ID No. EU 1.1, 20.9 million Btu/hour maximum heat input) predates NSPS Dc, as it was manufactured in 1968 (per the 2006 compliance inspection report). Facility Specific Conditions and Limitations SECTION 2 - SPECIFIC LIMITATIONS AND CONDITIONS 2.1 Emission Source(s) and Control Devices(s) Specific Limitations and Conditions The emission source(s)and associated air pollution control device(s)and appurtenances listed below are subject to the following specific terms,conditions,and limitations,including the testing,monitoring,record keeping,and reporting requirements as specified herein: A. Boiler (ID No. EU 1.1) Boiler ID No. EU LI is a 500 HP Cleaver Brooks now burning primarily propane. This boiler runs 2417, between low fire and high firing, as needed. They usually shut this boiler down from November through Mid-March (wintertime) as there is no paving of asphalt during this time. Boiler startup was 2116117, and runs 2417. The following table provides a summary of limits and standards for the emission source(s)described above: Regulated Pollutant Limits/Standards Applicable Regulation Particulate Matter 0.41 lb/million Btu 15A NCAC 2D.0503 Sulfur Dioxide 2.3 pounds per million Btu heat input 15A NCAC 213.0516 Visible Emissions 20 percent opacity 15A NCAC 2D.0521 Volatile organic compounds See Section 2.2 A.1 15A NCAC 2D.0958 Odors State-enforceable only 15A NCAC 213.1806 See Section 2.2 A.2 Sulfur Dioxide See Section 2.2 A.3 15A NCAC 2Q.0317 (PSD Avoidance) Hazardous Air Pollutants See Section 2.2 A.4 15A NCAC 2Q.0317 (MACT Avoidance) Slurry Pavers Compliance Inspection 3/29/17 Page 5 of 19 1. 15A NCAC 2D.0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS a. Emissions of particulate matter from the combustion of natural gas,cutter stock,Nos.2,4,5,or 6 fuel oil, that are discharged from this source(ID No.EU 1.1)shall not exceed 0.41 pounds per million Btu heat input. Firing of propane produces extremely low particulate emissions—compliance is indicated. Testing [15A NCAC 2Q.0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the results of this test exceed the limit given in Section 2.1 A.La above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D.0503. Monitoring/Recordkeeping/Reporting [15A NCAC 2Q.0508(f)] c. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing of natural gas, cutter stock,Nos.2,4,5,or 6 fuel oil in this source(ID No.EU 1.1). 2. 15A NCAC 2D.0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES a. Emissions of sulfur dioxide from this source (ID No.EU 1.1)shall not exceed 2.3 pounds per million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels,wastes,ores,and other substances shall be included when determining compliance with this standard. Firing of propane produces extremely low S02 emissions—compliance is indicated Testing [15A NCAC 2Q.0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the results of this test are above the limit given in Section 2.1 A.2.a above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D.0516. c. Cutter stock sulfur content testing shall be performed on-site in accordance with ASTM method D-4294 or shall be determined and certified by an off-site independent laboratory using an approved test method. The sulfur content testing shall be completed with an X-ray Sulfur Meter. The calibration of the testing meter shall be completed using the manufacturer's specifications. The sampling and testing requirements shall include the following: i. The cutter stock stored in Tank No.25 (ID No.EU 6.4)or Tank No. 36(ID No.EU 6.5) shall be sampled from the tank sampling valve and tested each day that cutter stock is transferred out of either tank for combustion. If the results of any tests(on-site by the Permittee and the off-site by the independent laboratory)are above the sulfur content limit given in Section 2.1 A.2.e below,the Permittee shall be deemed in noncompliance with 15A NCAC 2D.0516. Firing primarily propane now—compliance is indicated. Monitoring/Recordkeeping [15A NCAC 2Q.0508(f)] d. No monitoring/recordkeeping is required for sulfur dioxide emissions from the firing of natural gas and No. 2 fuel oil in this source(ID No.EU 1.1). e. The maximum sulfur content of any cutter stock,Nos.4,5,or 6 fuel oil received and burned in this source (ID No.EU 1.1)shall not exceed 2.1 percent by weight. The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0516 if the sulfur content of the fuel exceeds this limit. Slurry Pavers Compliance Inspection 3/29/17 Page 6 of 19 f. To ensure compliance,the Permittee shall monitor the sulfur content of the Nos.4, 5 or 6 fuel oil by using fuel oil supplier certification per shipment received. The results of the fuel oil supplier certifications shall be recorded in a logbook(written or electronic format)on a quarterly basis and shall include the following information: i. the name of the fuel oil supplier; ii. the maximum sulfur content of the fuel oil received during the quarter; iii. the method used to determine the maximum sulfur content of the fuel oil;and iv. a certified statement signed by the responsible official that the records of fuel oil supplier certification submitted represent all of the Nos.4,5,or 6 fuel oil fired during the period. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 if the sulfur content of the fuel oil is not monitored and recorded. g. To ensure compliance,the Permittee shall monitor the sulfur content of the cutter stock by using the on-site testing results per the procedure described in Section 2.1 A.2.c above or by having an off-site independent laboratory determine and certify the sulfur content using an approved test method. The results of both the on-site and off-site testing shall be recorded in a logbook(written or electronic format)and shall include the following information: i. date of samples obtained and tested from Tank No.25 or Tank No. 36; ii. the maximum sulfur content of the cutter stock combusted during the quarter; iii. a certified statement signed by the responsible official that the records of cutter stock on-site and off- site testing submitted represent all of the cutter stock fired during the period. The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0516 if the sulfur content of the cutter stock is not monitored and recorded. Reporting [15A NCAC 2Q.0508(f)] h. No reporting is required for sulfur dioxide emissions from the firing of natural gas and No.2 fuel oil in this source(ID No.EU 1.1). i. The Permittee shall submit a summary report of the Nos.4,5,or 6 fuel oil supplier certifications and on- site cutter stock testing results postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six- month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. 3. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS a. Visible emissions from this source(ID No.EU 1.1) shall not be more than 20 percent opacity when averaged over a six-minute period. However,six minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. In no event shall the six- minute average exceed 87 percent opacity. Zero visible emissions were observed for ALL emissions sources facility-wide. Compliance with 2D.0521 was indicated facility-wide for ALL emission sources. Testing [15A NCAC 2Q.0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the results of this test exceed the limit given in Section 2.1 A.3.a above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. Monitoring/Recordkeeping [15A NCAC 2Q.0508(f)] c. No monitoring/recordkeeping is required for visible emissions from the firing of natural gas or No.2 fuel oil in this source(ID No.EU 1.1). Slurry Pavers Compliance Inspection 3/29/17 Page 7 of 19 d. To assure compliance,once a month while firing cutter stock/Nos.4, 5,or 6 fuel oil,the Permittee shall observe the emission points of this source(ID No.EU 1.1)for any visible emissions above normal. The monthly observation must be made for each month of the calendar year period to ensure compliance with this requirement. If visible emissions from these sources are observed to be above normal,the Permittee shall either: i. take appropriate action to correct the above-normal emissions as soon as practicable and within the monitoring period and record the action taken as provided in the recordkeeping requirements below,or ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A NCAC 2D.2610(Method 9)for 12 minutes is below the limit given in Section 2.1 A.3.a above. If the above-normal emissions are not corrected per i. above or if the demonstration in ii.above cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D.0521. e. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each observation and/or test noting those sources with emissions that were observed to be in noncompliance along with any corrective actions taken to reduce visible emissions;and iii. the results of any corrective actions performed. The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0521 if these records are not maintained. The facility has been keeping ALL required records in the logbook. Compliance is indicated with ALL recordkeeping requirements facility-wide. Reporting [15A NCAC 2Q.0508(f)] f. No reporting is required for visible emissions from the firing of natural gas or No.2 fuel oil in this source (ID No.EU 1.1). g. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. The last semi-annual Summary report was received 1/17/17. There were no deviations in the permitted requirements for this requirement, nor for ANY other permitted requirement facility-wide. The facility ACC was received 2128117, no deviations. Compliance is indicated for ALL facility-wide permit reporting requirements. 4. 15A NCAC 2Q.0317:AVOIDANCE CONDITIONS for 15A NCAC 2D.1111,40 CFR Part 63, Subpart JJJJJJ,"National Emission Standards for Hazardous Air Pollutants for Industrial,Commercial,and Institutional Boilers at Area Sources" a. In order to avoid the applicability of 40 CFR 63 Subpart JJJJJJ,"Industrial,Commercial,and Institutional Boilers Area Sources,"the Permittee shall operate the emission source(ID No.EU 1.1)as follows: i. Gaseous-fuels are not combined with any solid fuels. ii. Liquid fuels are burned only during periods of gas curtailment,gas supply interruption,startups,or periodic testing on liquid fuel. Slurry Pavers Compliance Inspection 3/29/17 Page 8 of 19 The facility is following this requirement. iii. Periodic testing of liquid fuel shall not exceed a combined total of 48 hours during any calendar year. [40 CFR 63.11195(e),63.11237] The facility is following this requirement. Definitions and Nomenclature b. For the purposes of this permit condition,the definitions and nomenclature contained in 40 CFR 63.11237 shall apply. Recordkeeping [15A NCAC 2Q 0508(f)] c. The Permittee shall maintain,and make available upon request,the following records: i. types of fuels combusted during periods of gas curtailment,gas supply interruption,and startups; ii. date and duration of periods of gas curtailment,gas supply interruption and startups;and iii. date and duration of periods of testing with liquid fuel. If the Permittee : i. fails to keep the above records; ii. combusts any solid fuels; iii. burns liquid fuels outside the periods indicated in condition a.ii. above or iv. tests the source burning liquid fuel for longer than 48 hours during any calendar year; the Permittee shall be deemed in non-compliance with 15A NCAC 2D.1111. The facility is keeping records and following these requirements. Reporting [15A NCAC 2Q 0508(f)] d. No reporting is required. B. Emission Unit Group 2 (ID No. EU 2), including: Storage Tank#1 (ID EU 2.1) Storage Tank#2 (ID EU 2.2) Storage Tank#3 (ID No. EU 2.3) Storage Tank#4 (ID No. EU 2.4) Storage Tank#6 (ID No. EU 2.5) Out of Service Storage Tank#7 (ID No. EU 2.6) Out of Service with associated fiber bed filter (ID No. F 001) Out of Service Storage Tank#10 (ID No. EU 2.7) Out of Service Storage Tank#15 (ID No. EU 2.8) Out of Service Storage Tank#16 (ID No. EU 2.9) Out of Service with associated fiber bed filter (ID No. F 002) Out of Service Storage Tank#18 (ID No. EU 2.10) Storage Tank#19 (ID No. EU 2.11) Storage Tank#20 (ID No. EU 2.12) Storage Tank#21 (ID No. EU 2.13) Slurry Pavers Compliance Inspection 3/29/17 Page 9 of 19 Storage Tank#22 (ID No. EU 2.14) Storage Tank#23 (ID No. EU 2.15) Storage Tank#33 (ID No. EU 2.17) Out of Service Storage Tank#34 (ID No. EU 2.18) Out of Service with associated fiber bed filter (ID No. F 003) Out of Service This is a facility total of 17 permitted storage tanks. The following facility storage tanks are being used at this time: Asphalt Storage for Tanks 1, 2, 3, 4, 18, 19, 20, 21, 22, and 23. The only other tanks being used is tank 25 (an insignificant source, ID No. I-EU-6.4)for ultra-low sulfur No. 2 fuel oil, and the process water tank from boiler(ID No. I-WRT-1). The following facility storage tanks are NOT being used at this time and are empty: 5, 6, 7, 8, 10, 15, 16, 33, 34, 35, and 36. Note— The facility may put a low-VOC additive in tank#16 in the near future, for which it is already permitted to do so. The facility has a total of 8 insignificant storage tanks (all empty except#25 and I-WRT-1) as previously stated): Emission Source I.D. Emission Source Description I-EU-3.1 450 gallon capacity recycle asphalt tank—in service I-EU-3.2 1500 gallon capacity recycle asphalt tank—out of service—may soon be removed I-EU-6.1 Storage tank#5A—out of service I-EU-6.3 Storage tank#8—out of service I-EU-6.4 Storage tank#25—storing ultra-low sulfur diesel I-ST-35 Storage tank#35—out of service I-ST-36 I Fuel oil storage tank#36 (75,000 gallon storage capacity)—out of service I-WRT-1 I Water reclamation tank—from boiler The following table provides a summary of limits and standards for the emission source(s)described above: Regulated Pollutant Limits/Standards Applicable Regulation Particulate Matter (For process rates up to 30 tons per hour) 15A NCAC 2D .0515 E=4.10XpO.6' (For process rates greater than 30 tons per hour) E=55.0x Po" -40 Where: E=allowable emission rate in pounds per hour P=process weight in tons per hour Visible Emissions 20 percent opacity 15A NCAC 2D.0521 Volatile Organic See Section 2.2.A.1 15A NCAC 2D.0958 Compounds Odors State-enforceable only 15A NCAC 2D.1806 See Section 2.2.A.2 Slurry Pavers Compliance Inspection 3/29/17 Page 10 of 19 Regulated Pollutant Limits/Standards Applicable Regulation Hazardous Air Pollutants See Section 2.2.A.4 15A NCAC 2Q.0317 (MACT Avoidance) 1. 15A NCAC 2D.0515: PARTICULATE EMISSIONS FROM MISCELLANEOUS INDUSTRIAL PROCESSES a. Emissions of particulate matter from these sources (ID Nos.EU 2.1 through EU 2.15,EU 2.17,and EU 2.18)shall not exceed an allowable emission rate as calculated by the following equations: (For process rates up to 30 tons per hour) E=4.1OxPo.67 (For process rates greater than 30 tons per hour) E=55.Ox Po"—40 Where E=allowable emission rate in pounds per hour P=process weight in tons per hour Liquid and gaseous fuels and combustion air are not considered as part of the process weight. No particulate, VE, or odors were observed from any storage tank. Compliance is indicated. Testing [15A NCAC 2Q.0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the results of this test are above the limits given in Section 2.1 B.La above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D.0515. No testing has been required for these tanks. Monitoring/Recordkeeping/Reporting [15A NCAC 2Q.0508(f)] c. The Permittee shall maintain production records such that the process rates"P"in tons per hour,as specified by the formulas contained above can be derived,and shall make these records available to a DAQ authorized representative upon request. The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0515 if the production records are not maintained or the types of materials and finishes are not monitored. The facility is keeping records and following these requirements. d. The Permittee shall take all reasonable precautions with any operation,process,handling,transportation, or storage facilities to prevent fugitive emissions from becoming airborne. e. No reporting is required for particulate matter from these sources (ID Nos.EU 2.1 through EU 2.15,EU 2.17,and EU 2.18). 2. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS a. Visible Emission from these sources (ID Nos.EU 2.1 through EU 2.15,EU 2.17,and EU 2.18) shall not be more than 20 percent opacity when averaged over a six-minute period. However,six minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity. Testing [15A NCAC 2Q.0508(f)] Slurry Pavers Compliance Inspection 3/29/17 Page 11 of 19 b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the results of the test are above the limit given in Section 2.1 B.2.a above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D.0521. No testing has been required. Monitoring/Recordkeeping [15A NCAC 2Q.0508(f)] c. To ensure compliance,once a month the Permittee shall observe the emission points of these sources (ID Nos.EU 2.1 through EU 2.15,EU 2.17,and EU 2.18) for any visible emissions above normal. The monthly observation must be made for each month of the calendar year period to ensure compliance with this requirement. If visible emissions from these sources are observed to be above normal,the Permittee shall either: i. take appropriate action to correct the above-normal emissions as soon as practicable and within the monitoring period and record the action taken as provided in the recordkeeping requirements below,or ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A NCAC 2D.2610(Method 9)for 12 minutes is below the limit given in Section 2.1 B.2.a above. If the above-normal emissions are not corrected per i. above or if the demonstration in ii.above cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D.0521. The facility is monitoring the VE monthly and keeping records. d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each observation and/or test noting those sources with emissions that were observed to be in noncompliance along with any corrective actions taken to reduce visible emissions;and iii. the results of any corrective actions performed. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not maintained. Reporting [15A NCAC 2Q.0508(f)] e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. Last report received 1/17/17. No deviations for any requirement facility-wide. Loading Rack East (ID No. EU 5.1) Loading Rack West(ID No. EU 5.2) with associated fiber bed filter (ID No. F 004) Railcar Loading Rack West(ID No. EU 5.3) The following table provides a summary of limits and standards for the emission source(s)described above: Regulated Pollutant Limits/Standards Applicable Regulation Particulate Matter (For process rates up to 30 tons per hour) 15A NCAC 2D.0515 E=4.10 X pO.17 (For process rates greater than 30 tons per hour) E=55.0x Po" -40 Where: E=allowable emission rate in pounds per hour P=process weight in tons per hour Slurry Pavers Compliance Inspection 3/29/17 Page 12 of 19 Regulated Pollutant Limits/Standards Applicable Regulation Visible Emissions 20 percent opacity 15A NCAC 2D .0521 Volatile Organic See Section 2.2 A.1 15A NCAC 2D.0958 Compounds Odors State-enforceable only 15A NCAC 2D .1806 See Section 2.2 A.2 Hazardous Air Pollutants See Section 2.2 A.4 15A NCAC 2Q.0317 (MACT Avoidance) 1. 15A NCAC 2D.0515: PARTICULATE EMISSIONS FROM MISCELLANEOUS INDUSTRIAL PROCESSES a. Emissions of particulate matter from these sources (ID Nos. 1. 15A NCAC 2D.0515: PARTICULATE EMISSIONS FROM MISCELLANEOUS INDUSTRIAL PROCESSES a. Emissions of particulate matter from these sources (ID Nos.EU 5.1,EU 5.2,and EU 5.3) shall not exceed an allowable emission rate as calculated by the following equations: (For process rates up to 30 tons per hour)E=4.10 x Po" (For process rates greater than 30 tons per hour) E=55.0 x Po"—40 Where E=allowable emission rate in pounds per hour P=process weight in tons per hour Liquid and gaseous fuels and combustion air are not considered as part of the process weight. In peak season, about April 1st, the facility averages loading about IS trucks per day. No truck loading was being done at the time of this inspection. The facility has not done any railcar loading since resuming asphalt storage. An Asphalt Ship (20,000 tons) should come mid April. Testing [15A NCAC 2Q.0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with and General Condition JJ. If the results of this test are above the limits given in Section 2.1 C.La above for particulate matter,the Permittee shall be deemed in noncompliance with 15A NCAC 2D.0515. No testing has been required. Monitoring/Recordkeeping/Reporting [15A NCAC 2Q.0508(f)] c. The Permittee shall maintain production records such that the process rates"P"in tons per hour,as specified by the formulas contained above can be derived,and shall make these records available to a DAQ authorized representative upon request. The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0515 if the production records are not maintained or the types of materials and finishes are not monitored. d. No reporting is required for the emissions of particulate matter from the loading racks (ID Nos.EU 5.1,EU 5.2,and EU 5.3). 2. 15A NCAC 2D.0521: CONTROL OF VISIBLE EMISSIONS Slurry Pavers Compliance Inspection 3/29/17 Page 13 of 19 a. Visible emissions from these sources(ID Nos.EU 5.1,EU 5.2,and EU 5.3) shall not be more than 20 percent opacity when averaged over a six-minute period. However,six minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity. Testing [15A NCAC 2Q.0508(f)] b. If emissions testing is required,the testing shall be performed in accordance with General Condition JJ. If the results of this test are above the limit given in Section 2.1 C.2.a above,the Permittee shall be deemed in noncompliance with 15A NCAC 2D.0521. Monitoring/Recordkeeping [15A NCAC 2Q.0508(f)] c. To ensure compliance,once a month the Permittee shall observe the emission points of these sources (ID Nos.EU 5.1,EU 5.2,and EU 5.3) for any visible emissions above normal. The monthly observation must be made for each month of the calendar year period to ensure compliance with this requirement. If visible emissions from these sources are observed to be above normal,the Permittee shall either: i. take appropriate action to correct the above-normal emissions as soon as practicable and within the monitoring period and record the action taken as provided in the recordkeeping requirements below,or ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A NCAC 2D.2610(Method 9)for 12 minutes is below the limit given in Section 2.1 C.2.a above. If the above-normal emissions are not corrected per i. above or if the demonstration in ii. above cannot be made,the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D.0521. No loading was occurring during inspection. The facility is monitoring the VE monthly and keeping the required records. d. The results of the monitoring shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each recorded action; ii. the results of each observation and/or test noting those sources with emissions that were observed to be in noncompliance along with any corrective actions taken to reduce visible emissions;and iii. the results of any corrective actions performed. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not maintained. Reporting [15A NCAC 2Q.0508(f)] e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. No deviations reported in last reporting period. 2.2 - Multiple Emission Source(s) Specific Limitations and Conditions A. Facility-wide affected emission sources The following table provides a summary of limits and standards for the emission source(s)described above: Regulated Pollutant Limits/Standards Applicable Regulation Volatile Organic Compounds Work Practice Standards 15A NCAC 2D.0958 Odors State enforceable only 15A NCAC 2D.1806 Odorous emissions must be controlled Sulfur Dioxide Facility-wide emissions less than 250 tons per 15A NCAC 2Q.0317 consecutive 12-months period Slurry Pavers Compliance Inspection 3/29/17 Page 14 of 19 Regulated Pollutant Limits/Standards Applicable Regulation Hazardous Air Pollutants Facility-wide emissions less than 10 tons per year of 15A NCAC 2Q.0317 any HAP and less than 25 tons per year of a combination of HAPs 1. 15A NCAC 2D.0958:WORK PRACTICES FOR SOURCES OF VOLATILE ORGANIC COMPOUNDS a. Pursuant to 15A NCAC 2D .0958,for all sources that use volatile organic compounds(VOC)as solvents, carriers,material processing media,or industrial chemical reactants,or in similar uses that mix,blend,or manufacture VOCs,or emit VOCs as a product of chemical reactions;the Permittee shall: i. store all material,including waste material,containing VOCs in tanks or in containers covered with a tightly fitting lid that is free of cracks,holes,or other defects,when not in use, ii. clean up spills of VOCs as soon as possible following proper safety procedures, iii. store wipe rags containing VOCs in closed containers, iv. not clean sponges,fabric,wood,paper products,and other absorbent materials with VOCs, v. transfer solvents containing VOCs used to clean supply lines and other coating equipment into close able containers and close such containers immediately after each use,or transfer such solvents to closed tanks,or to a treatment facility regulated under section 402 of the Clean Water Act, vi. clean mixing,blending,and manufacturing vats and containers containing VOCs by adding cleaning solvent and close the vat or container before agitating the cleaning solvent. The spent cleaning solvent shall then be transferred into a closed container,a closed tank or a treatment facility regulated under section 402 of the Clean Water Act. b. When cleaning parts with a solvent containing a VOC,the Permittee shall: i. flush parts in the freeboard area, ii. take precautions to reduce the pooling of solvent on and in the parts, iii. tilt or rotate parts to drain solvent and allow a minimum of 15 seconds for drying or until all dripping has stopped,whichever is longer, iv. not fill cleaning machines above the fill line, v. not agitate solvent to the point of causing splashing. Monitoring[15A NCAC 2Q.0508(f)] c. To ensure compliance with paragraphs(a)and(b)above,the Permittee shall,at a minimum,perform a visual inspection once per month of all operations and processes utilizing VOCs. The inspections shall be conducted during normal operations. If the required inspections are not conducted the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D.0958. No violations were observed during the time of inspection. The facility is performing the monthly inspections, keeping records, and reporting on time. Compliance is indicated with all 2D.0958 requirements. Recordkeeping [15A NCAC 2Q.0508(f)] d. The results of the inspections shall be maintained in a logbook(written or electronic format)on-site and made available to an authorized representative upon request. The logbook shall record the following: i. the date and time of each inspection;and ii. the results of each inspection noting whether or not noncompliant conditions were observed. If the required records are not maintained the Permittee shall be deemed to be in noncompliance with 15A NCAC 2D.0958. Reporting [15A NCAC 2Q.0508(f)] e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each Slurry Pavers Compliance Inspection 3/29/17 Page 15 of 19 calendar year for the preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. State-enforceable only 2. 15A NCAC 2D.1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS a. 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. No objectionable odors were observed at the facility during the inspection. Compliance is indicated. 3. 15A NCAC 2Q.0317:AVOIDANCE CONDITION for 15A NCAC 2D.0530:PREVENTION OF SIGNIFICANT DETERIORATION a. In order to avoid applicability of 15A NCAC 2D.0530(g),the facility shall discharge into the atmosphere less than 250 tons of sulfur dioxide per consecutive 12-month period. Testing [15A NCAC 2Q.0508(f)] b. If emissions testing is required,the Permittee shall perform such testing in accordance with General Condition JJ. If the results of this test are above the limit given in Section 2.2 A.3.a the Permittee shall be deemed in noncompliance with 15A NCAC 2D.0530. Monitoring/Recordkeeuing [15A NCAC 2Q.0508(f)] c. The Permittee shall keep monthly records of the amount of each fuel used, sulfur content of each fuel including certification of the fuel oils and the cutter stock,and amount of oxidized asphalt produced in a logbook(written or in electronic format). The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0530 if the sulfur content of the fuel is not monitored. Firing of propane produces extremely low S02 emissions. The facility has burned no fuel oil(all ultra-low sulfur No. 2) since 516115. The facility keeps the records of fuel usage and reports on time— compliance is indicated with PSD requirements. d. The use of fuel in the combustion emission unit(ID No.EU 1.1)shall be limited such that sulfur dioxide emissions shall not exceed 250 tons for any consecutive 12-month period on a facility-wide basis. Calculations shall be made monthly and recorded in a log(written or in electronic format),according to the following formula: T=[U x 0.6(lb sulfur dioxide/million cubic feet)+V x 142(lb sulfur dioxide)/1000 gallons)x S1 +W x 150(lb sulfur dioxide)/1000 gallons)x S2+X x 157(lb sulfur dioxide)/1000 gallons)x S3+Y x 157(lb sulfur dioxide)/1000 gallons)x S4+Z x 157(lb sulfur dioxide)/1000 gallons)x S5+ 1.43 lbs/ton x A]/ 2000 Where: T is the total actual emissions of sulfur dioxide in pounds U is the total amount of Natural gas used in the combustion units in cubic feet V is the total amount of No.2 fuel oil used in combustion units in 1,000 gallons W is the total amount of No.4 fuel oil used in combustion units in 1,000 gallons X is the amount of cutter stock used in the combustion units in 1,000 gallons Y is the amount of No. 5 fuel oil used in the combustion units in 1,000 gallons Z is the total amount of No.6 fuel oil used in the combustion unit in 1,000 gallons A is the total amount of oxidized asphalt produced in the converters in tons S1 is the percent sulfur in the No.2 fuel oil Slurry Pavers Compliance Inspection 3/29/17 Page 16 of 19 S2 is the percent sulfur in the No.4 fuel oil S3 is the percent sulfur in the cutter stock S4 is the percent sulfur in the No. 5 fuel oil S5 is the percent sulfur in the No. 6 fuel oil The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0530 if the above records are not kept or if the sulfur dioxide emissions exceed the limit in Section 2.2 A.3.a. The facility is performing the monthly calculations and keeping and reporting these records. Reporting [15A NCAC 2Q.0508(f)] e. The Permittee shall submit a summary report,acceptable to the Regional Air Quality Supervisor,of monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. The report shall contain the following: i. The monthly sulfur dioxide emissions for the previous 17 months. The emissions must be calculated for each of the 12-month periods over the previous 17 months; ii. The monthly quantities of natural gas,No.2 fuel oil,No.4 fuel oil,cutter stock,No. 5 fuel oil,and No. 6 fuel oil consumed,and amount of oxidized asphalt produced for the previous 17 months; iii. The average sulfur contents for No.2 fuel oil,No.4 fuel oil,cutter stock,No. 5 fuel oil,and No. 6 fuel oil. All instances of deviations from the requirements of this permit must be clearly identified. 4. 15A NCAC 2Q.0317:AVOIDANCE CONDITION for 15A NCAC 2D.1111:MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY a. In order to avoid applicability of this regulation,the facility shall discharge into the atmosphere less than 10 tons of any individual HAP and less than 25 tons of total HAPs per consecutive 12-month period. Monitoring/Recordkeeping [15A NCAC 2Q.0508(f)] b. Calculations of HAP emissions per month shall be made at the end of each month. HAP emissions shall be determined by multiplying the total amount of each type of HAP-containing material consumed during the month by the HAP content of the material. Calculations and the total amount of HAP emissions and individual HAP emissions shall be recorded monthly in a logbook(written or electronic format). The Permittee shall be deemed in noncompliance with 15A NCAC 2D.1111 if the amounts of HAP containing materials or the HAP emissions are not monitored and recorded. The Permittee shall also be deemed in noncompliance with 15A NCAC 2D.1111 if the HAP emissions exceed the above limits. Because the facility is not processing any asphalt, but is only storing and distributing asphalt and using propane in the boiler, very low HAP emissions are occurring. The facility continues to monitor, record and report their HAP emissions as required. Compliance is indicated. Reporting [15A NCAC 2Q.0508(o] c. The Permittee shall submit a summary report of the monitoring and recordkeeping requirements postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December and July 30 of each calendar year for the preceding six-month period between January and June. All instances of deviations from the requirements of this permit must be clearly identified. The report shall contain the following: i. Individual HAP emissions during the six,previous twelve-month periods. ii. Total HAP emissions during the six,previous twelve-month periods. All instances of deviations from the requirements of this permit must be clearly identified. Slurry Pavers Compliance Inspection 3/29/17 Page 17 of 19 Inspection Results I was escorted during the inspection by Mr. Callahan, Plant Manager. The plant has not performed oxidation since August of 2007. The facility had no asphalt processing or storage from 2009 to December 2012. With the most recent permit revision (T18) on 6/26/14, the preheaters, converters, and thermal oxidizer have all been removed from the permit. Up until then, they had the equipment to process (oxidize the asphalt by bubbling heated air through it, however, that the facility has done no oxidization since 2007; this process occurred in the converters. Beginning January 2013, the facility started as an asphalt storage and distribution terminally only. The facility now receives asphalt by barge, about 1 to 2 times per year(about 8 million gallons total). They heat the asphalt with the 500 hp Cleaver Brooks boiler only from about March through October(about 280-300 F). The facility converted from No. 2 ultra low sulfur fuel oil to LP gas on 3/10/14, and now burns primarily LP gas. The boiler was operating at the time of inspection. The boiler is rated for 200 psi steam, but is limited to 150 psi, and generally runs around 70 psi. The boiler was observed operating at 135 psi, and 0%VE. In the winter months, the asphalt is not heated, yet the temp still maintains about 70-90F. The asphalt is then trucked out only, no railcar loading since 2007. The facility has the following current tank storage: Asphalt in tanks 1, 2, 3, 4, 18, 19, 20, 21, 22 and 23. The facility stores ultra-low sulfur No. 2 fuel oil in Tank 25. All other tanks are empty. No truck loadout nor railcar loadout was occurring at the time of inspection. There was no opacity noticed nor objectionable odors detected during the time of inspection. The parts washer is a Safety Kleen,using"Safety Kleen Premium Solvent", which is primarily naphtha or mineral spirits. No uncovered containers, solvent cleaning rags, solvent odors etc. were observed, indicating compliance with 2D .0958. The monthly work practice observation log is being kept. Permit Recordkeeping and Reporting Requirements Records for the monthly VE observations of the boiler, tanks, and the loading racks were complete for the period since the last inspection. All required records are being kept including the amount of propane and No. 2 fuel oil and the % sulfur content. The facility submitted the required semi-annual reports for 2014 (1/25/14 and 7/23/14); 2015 (1/27/15 and 7/15/15); 2016 (1/27/16 and 7/18/16); and 2017 (1/17/17). These reports indicated compliance with all reporting requirements —no permit deviations. Compliance History The facility(SemMaterials, a previous owner)was assessed a civil penalty of$2,000.00 on 07/28/08 for failing to submit their emissions inventory by 06/30/08. Slurry Pavers Compliance Inspection 3/29/17 Page 18 of 19 The facility(Owens Corning, a previous owner) was assessed a civil penalty of$1,000.00 on 07/20/06 for failing to submit their emissions inventory by 06/30/06. A request for remission was denied on 10/13/06. Note that the current owners, Slurry Pavers, have had no NOVs or NODS. Facility Emissions The facility did not perform any asphalt processing or storage from 2009 through December 2012. IBEAM "Fees—Yearly pollutant data" shows zero emissions for the last 3 years (2010-2012)—this is correct. Conclusions, Comments, and Recommendations With revision T12, Owens Corning (a previous owner)was permitted to remove Preheater 1 and replace it with Preheater 4. The new heater has a 1.53 mmBtu/hr higher rating of 9.9 mmBtu/hr. They also were permitted to add a third converter. Another change was the ability to burn natural gas/propane and cutter stock. Cutter stock is a by-product of processing and has similar properties to No. 5 fuel oil. Preheater 4 has not been installed. Although Preheater 1 was removed from the permit, they may continue to use it and follow the old permit conditions for it until Preheater 4 is installed. They will not operate Preheater 1 once No. 4 is installed. With revision T13, SemMaterials became the new facility owner. The five year renewal was revision T14. With revision T15, SemMaterials Energy Partners became the new facility owner. With revision T16, the facility name was changed to B1ueKnight Energy Partners (BKEP). Slurry Pavers bought this facility from B1ueKnight Energy Partners. This ownership change is reflected in permit revision T17. With revision T18, the facility made major changes by removing many emission sources, as listed in the table below, that would allow them to become a Synthetic Minor facility if they so desired: Pages Section Description of Change(s) Attachment Insignificant Activities +Remove tank burner#6 (ID No. I-EU-1.6), tank burner #16 (ID No. I-EU-1.7)and storage tank#9(ID No. I-EU- 6.2) All All +Update dates and permit revision number 3 Permitted Items +Remove No. 3 preheater(ID No. EU 1.3) +Remove No. 4 preheater(ID No. EU 1.5) +Remove three (Nos. 1, 2 and 3)converters (ID Nos. EU 4.1,4.2 and 4.3)and associated thermal oxidizer/preheater (ID No. TO 001) +Remove 15A NCAC 2Q .0501(c)(2)footnote language associated with ID Nos. EU 1.5 and EU 4.3 Slurry Pavers Compliance Inspection 3/29/17 Page 19 of 19 Page(s) Section Description of Change(s) 4-6 2.1 A +Remove No. 3 preheater(ID No. EU 1.3) and No. 4 preheater ID No. EU 1.5 from Section 2.1 A 4-11 "Testing"paragraphs +Update testing paragraphs to refer solely to General Condition JJ and header citations to 15A NCAC 2Q .0508(f) 6-11 "15A NCAC 2D .0521" +Update 15A NCAC 2D .0521 monitoring paragraphs to paragraphs refer solely to 15A NCAC 2D .2610 instead of 15A NCAC 2D .2601 7 2.1 A.4 +Add GACT JJJJJJ avoidance condition to boiler ID No. EU 1.1 9-14 (T17) 2.1 C (T17) +Remove this entire section consisting of three (Nos. 1, 2 and 3) converters (ID Nos. EU 4.1,4.2 and 4.3) and associated thermal oxidizer/preheater(ID No. TO 001). 12 2.2 A.1 +Remove"and whose emissions of VOC are greater than 15 pounds per day"to reflect the current 15A NCAC 2D .0900 rules 13 2.2 A.3 +Remove No. 3 preheater(ID No. EU 1.3),No. 4 preheater (ID No. EU 1.5),thermal oxidizer/preheater(ID No. TO 001)and Nos. 1,2 and 3 converters (ID Nos. EU 4.1,4.2 and 4.3) from Section 2.2 A.3 15-end 3 +Update General Conditions to version 3.6 *Note: The Permittee was subject to the New Source Performance Standards for Asphalt Processing and Asphalt Roofing Manufacture(40 CFR 60, Subpart UU)for one converter(ID No.EU 4.3). However, the No. 3 convertor (ID No. EU 4.3) was removed as part of the 6/26/14 renewal so the facility is no longer subject to NSPS Subpart UU. As described in the Permit Application Summary,NSPS Subpart UU is only applicable to saturators or mineral handling and storage facilities constructed/modified after November 18, 1980 and asphalt storage tanks or blowing stills constructed/modified after May 26, 1981. The boiler(ID No.EU 1.1,20.9 million Btu/hour maximum heat input)predates NSPS Dc,as it was manufactured in 1968 (per the 2006 compliance inspection report). The facility appeared to be in compliance with their air permit at the time of the inspection.